On 17 March 2026, new regulations will come into force expanding the scope of Poland’s Electronic Transport Monitoring System (SENT) to include clothing and footwear. The changes will particularly affect companies in the fashion industry, e-commerce businesses, retail chains, and the transport and logistics sector. Failure to submit required notifications or submitting incorrect data may result in severe financial penalties—up to 46% of the gross value of the goods and no less than PLN 20,000. The scale of the changes and their potential consequences mean that companies now face the final opportunity to prepare their organizations safely for the new obligations. For many businesses, this will be their first encounter with the system for monitoring goods transport and will introduce a new element into everyday operational activities.
A new category of goods within the SENT system
The SENT system, operating since 2017 and used to monitor the road and rail transport of selected goods considered by lawmakers to carry a higher risk of tax abuse, will now be extended to another group of products. From 17 March 2026, selected categories of clothing and footwear will be subject to mandatory reporting.
Until now, the system mainly covered fuels, alcohol, certain types of waste, and specific agricultural products. Expanding the list of monitored goods means that a broad segment of the textile and footwear market will now fall under supervision. In practice, a significant portion of standard warehouse deliveries—both domestic and imported—within the retail and e-commerce sectors may become subject to reporting requirements. The objective of these changes is to reduce VAT fraud and increase transparency across supply chains.
Although the regulations formally take effect on 17 March 2026, companies should be operationally ready well in advance. The process of analysis, implementation, and team training requires time. Delaying preparations until the last moment significantly increases the risk of errors, which in the case of SENT can be extremely costly.
“Implementing SENT within an organization does not end with technical registration in the PUESC system,” explains Tomasz Bełdyga, Partner in the Indirect Tax Team and Head of Customs and International Trade at KPMG Poland. “In practice, it requires a comprehensive review of supply chains, identification of transports subject to reporting, verification of CN product classifications, and clarification of reporting responsibilities. It is also necessary to develop procedures for updating and verifying the accuracy of data—such as weight, quantity, and delivery location—prepare contingency scenarios in case the system becomes unavailable, and train logistics, accounting, and tax teams.”
Obligations not only for carriers
The new regulations do not apply solely to transport companies. The scope of responsibility depends on the type of shipment. In the case of transport starting in Poland, the obligation lies with the sending entity. When goods are transported from another EU country or from outside the EU to Poland, the receiving entity is responsible for the notification. In the case of transit through Poland, the reporting obligation falls on the carrier.
“In the SENT system, assigning the primary reporting obligation to one party in the transaction does not release other participants from fulfilling their own independent obligations,” explains Maciej Przybył, Manager in the Indirect Tax Team at KPMG Poland. “At the same time, the reporting obligation arises only when the transport is directly linked to a transaction subject to VAT. In practice, this means companies must correctly identify the business transaction associated with the given shipment.”
Severe penalties and operational risks
The SENT Act provides for a financial penalty of 46% of the gross value of the goods—no less than PLN 20,000—for failing to submit a report or for providing incorrect data. In addition, companies must take into account operational risks such as vehicle detention, suspension of deliveries, delays in fulfilling contracts, and potential reputational damage.
In the fashion industry, where seasonality and delivery timing are critical, operational disruptions may prove more damaging than the administrative penalties themselves.
“The SENT regulation does provide certain exemptions and exceptions, for example for postal operators handling shipments that meet the definition of a postal parcel,” says Przybył. “However, in practice most companies in the retail sector do not meet the conditions necessary to benefit from these exclusions.”
Additional burdens for the transport and logistics sector
Transport companies in particular should pay close attention to the requirement to verify the reference number before a shipment begins. The number remains valid for ten days, and its absence may result in the immediate suspension of the transport.
In practice, this will require integration of operational processes with clients, updates to driver instructions, and the introduction of systems for formal verification of transport documentation. Without appropriate procedures, disputes may arise between carriers and transport contractors regarding liability for potential penalties.
Source: CEO.com.pl
