Contents
In brief
- The adviser prepares the report in two copies. The company sends one to the WITD by 28 February of the following year and keeps the other at its registered office for 5 years.
- The form is set out in the Regulation of 14 August 2012 (consolidated text, Dz.U. 2023 item 24).
- The report does not include quantities for which ADR does not require orange-coloured plates, or residues in empty uncleaned packagings and tanks.
- A late report costs from PLN 200 to PLN 5,000, depending on how many days have passed since the deadline.
- An adviser who fails to prepare the report may lose the certificate for 3 years.
Who prepares the DGSA annual report and who sends it?
The duties are split. The adviser prepares the annual report in two copies and signs it, giving their name and adviser's certificate number (Article 41(1) of the Polish Act on the transport of dangerous goods, the Act). If the company has several advisers, one of them, named by the company, prepares the report (Article 41(2)).
Sending it is the responsibility of the company, that is, the participant in the carriage. Article 16(1) requires one copy to be sent by 28 February each year for the previous year, to the WITD competent for the participant's registered office or place of residence. The second copy stays at the registered office for 5 years from the date of sending.
The duty does not apply only to carriers. The WITD in Bydgoszcz points out that the report is also submitted by other participants in road carriage, including consignors and unloaders. If your company has an adviser because it packs and loads dangerous goods, the report applies to you too. I explain when an adviser is mandatory in my article does your company need a DGSA.
The deadline: 28 February and the cost of being late
The report for 2026 must be sent by 28 February 2027. The WITD in Łódź explains that when sending through Poczta Polska (the Polish Post), the date of posting counts, while with another operator the date of receipt by the office counts. If you send by courier in the last days of February, what matters is the day the letter reaches the inspectorate.
For late submission, the WITD imposes a fine under Annex 1 to the Act, item 6.3:
| Delay from 28 February to the date of sending | Fine |
|---|---|
| less than 14 days | PLN 200 |
| at least 14 days | PLN 2,000 |
| at least 3 months | PLN 5,000 |
Legal status: consolidated text of the Act, Dz.U. 2024 item 643. The adviser also bears consequences. The Act gives failure to prepare the annual report as an example of a serious breach, for which the Director of Transportowy Dozór Techniczny (TDT) withdraws the adviser's certificate, and a new one can be obtained only after 3 years (Article 45).
The report form and what to enter
The form and how to complete it are set out in the Regulation of the Polish Minister of Transport, Construction and Maritime Economy of 14 August 2012 on the form of the annual report on activities in the transport of dangerous goods and how to complete it. The current form was introduced by the amending regulation of 2 June 2022. The current consolidated text is Dz.U. 2023 item 24.
The general part of the form includes:
- Type of transport: road (part A), rail (part B) or inland waterways (part C). Only one is ticked.
- Identification of the participant: name as in the Polish business registers (KRS or CEIDG), tax number (NIP), registered office address and telephone.
- A brief description of accidents or incidents with the date and place, stating whether they had to be reported under ADR 1.8.5 and, if so, to which authority the report was submitted.
- Remarks.
- Adviser's details: name, certificate number, country of issue (if not Poland), certificate expiry date, signature, date of preparation, plus the name and signature of the participant.
In point 3, for road transport, you can also describe events that did not have to be reported, if the adviser thinks they will help to find weak points. In my view this option is worth using in moderation. One minor event described together with conclusions shows that the company catches problems before they turn into an accident.
Part A: quantities of goods in road transport
Part A is a table of quantities. Quantities are given separately for each class, in order of class number, and for high consequence dangerous goods additionally for each UN number. The columns break them down by method of carriage (in tanks, in packages, in bulk, in MEMUs) and type of operation (consigning, packing, filling, loading, carriage, unloading).
The units are set out in the explanatory notes to the form:
| Goods | Unit |
|---|---|
| articles | gross mass in kg |
| class 1 | net explosive mass in kg, to 0.01 |
| solids, liquefied, refrigerated liquefied and dissolved gases | net mass in kg |
| liquids and compressed gases | litres, or gross kg, or net kg |
| class 7 | becquerels or grams |
Other quantities are rounded to whole units. Empty boxes are filled with an "X", and the signatures of the adviser and the participant go on the first and last pages of the form.
What you do not enter in the report
According to the instructions for completing the form, the report does not cover dangerous goods:
- carried entirely outside Poland,
- contained in empty uncleaned packagings, tanks, containers and vehicles,
- in quantities for which ADR does not require the transport unit to display orange-coloured plates.
The last point matters a lot in practice. Carriage under the ADR 1.1.3.6 exemption and in limited quantities that do not require plates does not go into the table. This is why such carriage must be kept separate from the rest during the year.
How to submit the report: paper or ePUAP?
The Act only speaks of sending a copy of the report. The method of receipt is described on the websites of the individual inspectorates. The WITD in Katowice accepts reports through e-Doręczenia or ePUAP (Polish public e-delivery services), with an electronic signature, or by traditional post after printing and signing. The inspectorates in Bydgoszcz, Szczecin and Radom give ePUAP inboxes.
The WITD in Łódź draws attention to signatures: whatever the form, the report is signed by the adviser and by the company's representatives as shown in the KRS, CEIDG or other register. The Katowice inspectorate notes that a document sent electronically must be digitally signed, so a scan of the paper form alone is not enough. Check your inspectorate's website before sending, as electronic channels may differ.
Where to get the data throughout the year
A report written from memory in February always has gaps. A good adviser collects data as they go. For my clients, a simple table updated monthly works well:
| What to record | Where to get it | What for |
|---|---|---|
| quantities by class and UN number | transport documents, warehouse system | part A of the form |
| method of carriage: tank, packages, bulk | transport documents, orders | part A columns |
| the company's role in each operation | contracts, transport orders | breakdown into consigning, loading, carriage etc. |
| carriage without plates (1.1.3.6, LQ) | points calculations, LQ marking | to be excluded, not part of the report |
| high consequence dangerous goods | list of UN numbers in ADR 1.10.3.1.2 | a separate row for each UN number |
| accidents, incidents, events | event log, accident reports | point 3 of the form |
| adviser's details and certificate validity | copy of the certificate | point 5 of the form |
Most common mistakes in reports
From the reports I check for new clients, these are what I most often correct:
- sending late, because the adviser waited for data from the sales department until the last week of February,
- no signature of the person representing the company, or a signature by someone with no authority,
- a company name different from the one in the KRS or CEIDG,
- including carriage in limited quantities and under the 1.1.3.6 exemption,
- litres and kilograms in one box without stating the unit,
- sending to the WITD for the warehouse location instead of the registered office,
- no second copy at the registered office, although it must be kept for 5 years.
A change of adviser during the year
Neither the Act nor the Regulation directly says who prepares the report when a company changes adviser during the year. Article 41 ties the report to the adviser appointed by the company, so in practice the adviser in post when the report is prepared does it. This is why, when changing adviser, you should agree in the contract on the handover of data for the past period: the register of quantities, events and reports.
Legal basis: Polish Act of 19 August 2011 on the transport of dangerous goods (consolidated text, Dz.U. 2024 item 643): Articles 16, 17, 41, 45 and 107 and Annex 1, item 6.3. Regulation of the Minister of Transport, Construction and Maritime Economy of 14 August 2012 on the form of the annual report on activities in the transport of dangerous goods and how to complete it (consolidated text, Dz.U. 2023 item 24). ADR 2025: 1.8.3.3, 1.8.5, 5.3.2, 1.1.3.6.
If February is approaching and the year's data is scattered across departments, start by listing the transport documents from recent months. As part of my permanent DGSA service, I keep the register up to date and prepare the report before the deadline, and you can ask questions during a free consultation.
FAQ
Questions and answers
Which WITD does the report go to if the company has warehouses in several voivodeships?
To one: the Voivodeship Road Transport Inspector competent for the registered office or place of residence of the participant (Article 16(1)(1)(a) of the Act). The location of the warehouses does not matter. The report concerns the activity of the whole participant, so it covers quantities from all locations.
Who signs the annual report?
The adviser, who gives their name and certificate number (Article 41(1) of the Act), and the participant, that is, a person authorised to represent the company. The form has a separate field for the name and signature of the participant, and the signatures go on the first and last pages.
Does one report cover both road and rail transport?
No. On the form you tick only one type of transport and complete the relevant part: A for road, B for rail, C for inland waterways. The rail report goes to the President of the Polish Office of Rail Transport, not to the WITD (Article 16(1)(1)(b)).
Does an accident report replace the description of the event in the annual report?
No. The company sends the accident report after a serious accident or incident within 14 days to the WITD competent for the place of the event (Article 17(1)). In the annual report, the event is briefly described in point 3, together with the authority to which the report was submitted.
Legal status: October 2026This article is for information only. It does not replace an analysis of a specific consignment.