Just before the obligations described by us last week came into force, the Minister of Finance and Economy published last Friday a Decree of 11 March 2026 amending the regulation on the exclusion of certain obligations in the field of reporting the carriage of goods (Journal of Laws, item 339).
These provisions aim to extend the exemptions from the monitoring system:
- if the transport is carried out by postal operators within the meaning of the Postal Law, in registered consignments – the exemption limit increases to a gross weight of 31.5 kg;
- for transports that are carried out by operators providing parcel delivery services within the meaning of the provisions of the EU Regulation 2018/644 (on cross-border parcel delivery services). According to this act, “parcel” means a postal item containing goods, regardless of whether they have a commercial value, other than a letter with correspondence, the weight of which does not exceed 31.5 kg;
- in a situation where the entity obliged to submit the application to the register is a party to a contract for the provision of comprehensive services on transported goods consisting in storage, reloading, packaging, organization of shipment and handling of their returns by an entity that: (i) has the status of an authorized AEO entrepreneur (ii) is a party to a cooperation agreement concluded with the Head of the National Tax Administration. It is a matter of comprehensive logistics services, the so-called fulfillment.
It is worth remembering that on the PUESC portal there are “FAQs” (questions and answers) in the scope of SENT: https://puesc.gov.pl/faq/-/categories/757341708.
Several of them concern domestic transport, which, however, are not strictly related to the sale transaction. It is worth paying attention to:
12.11. I transport goods to fairs, fairs, bazaars or visit customers (door-to-door trade), but I don’t know if and how much will be sold. When I return, I issue invoices on the basis of the WZ. Is such transport subject to registration with SENT?
For all the transported goods, a so-called self-declaration (as the sender and the receiving entity) should be made and in the “remarks” field it should be added that the unsold goods will be transported on the return journey. On the way back, the driver should have documents confirming the sale, e.g. receipts, invoices, WZ documents, on the basis of which the invoice will be inserted later. Upon your return, you should “close the application” by stating the number of remaining (unsold) shoes.
12.12. Is the movement of goods between one’s own warehouses or stores subject to notification to the SENT system?
If the transported goods are accompanied by a document confirming inter-warehouse transfers (the so-called MM) containing the data referred to in Article 3(7) of the Act on the System of Monitoring the Road and Rail Transport of Goods and Trade in Heating Fuels, then the transport of these goods is not subject to notification in the SENT system.
12.23. I send my own goods from a rented warehouse in Krakow to Warsaw, where I have a stationary store (located in a rented premises in a shopping mall). Should I submit a SENT application?
No. The transport of clothing and footwear between a warehouse and a stationary store, which is not related to the performance of activities subject to VAT is understood as a warehouse transfer. Therefore, if the transported goods are accompanied by a document confirming inter-warehouse transfers containing the data referred to in Article 3(7) of the Act on the System of Monitoring the Road and Rail Transport of Goods and Trade in Heating Fuels, then the transport of these goods is not subject to notification in the SENT system.
12.24. I transport shoe patterns. I transport the designs for presentation to customers, including trade fairs. Designs are not goods for sale. Is the transport of shoe patterns subject to notification to SENT?
By virtue of the Act, the SENT system covers, m.in, a supply within the meaning of the Value Added Tax Act, hence the transport of shoe samples that are not intended for commercial trade is not subject to reporting to the SENT register.
The driver may present documents confirming transport to the fair (e.g. transport order, confirmation of participation in the fair, “buy-out” of the exhibition space, receipt of delivery). The second example can be the transport of different shoe patterns with the same number, e.g. No. 37.
