e-TOLL Poland for trucks from Ukraine

A truck from Lviv clears the Korczowa border crossing at six in the morning and a few minutes later joins the A4 motorway. The RMPD filing is in, the locator number is in it, and the driver's e-TOLL PL app glows green in SENT mode. Near Rzeszów a road transport inspector stops the truck and sees within a minute that this tractor unit does not exist in the e-TOLL system. The position was reaching the SENT registry, but the road toll was not being paid, because these are two separate registrations.

This article explains e-TOLL, Poland's electronic road toll for vehicles over 3.5 tonnes, for a carrier based in Ukraine: who pays, how a non-EU company registers, what transmits the position, how payment works and what mistakes cost. The rules were checked against the statute as it stood on 23.10.2026, including the changes in force since 21.09.2026.

In brief: e-TOLL is paid by every vehicle with a gross vehicle weight (DMC) above 3.5 t, any combination built on such a vehicle and every bus, on a network of about 5,870 km (art. 13 ust. 1 pkt 3 of the Public Roads Act) · before the first tolled section the company registers the truck in the online customer account, links and activates a device and gives the driver its number, otherwise the driver must refuse the journey · the position comes from one of three devices, the free e-TOLL PL app, a portable OBU or a fitted external locating system (ZSL) · since 1 February 2026 a kilometre for a vehicle of 12 t or more in Euro 5 or 6 costs 0.56 zł on motorways and expressways and 0.42 zł on other national roads · a prepaid account opens from 20 zł, while deferred payment needs a security of at least 2,000 km × rate × 1.3 per vehicle · unpaid toll costs the owner 1,500 zł, about 17,310 hryvnias at the National Bank of Ukraine rate of 11.5401 per zł on 23.10.2026, and the driver separately risks a 1,500 zł ticket · a paid e-TOLL trip does not mean the SENT registry can see the position for RMPD.

e-TOLL applies to a Ukrainian truck exactly as it does to a Polish one, because the duty depends on the vehicle's weight and the tolled road, not on the country of registration. Registration is done online in the customer account with an e-mail address and password, at a customer service point or through a fuel card issuer. Payment is either prepaid from a balance or monthly against a security, and the position is sent by a phone, an OBU or a ZSL.

Who has to pay e-TOLL

Every motor vehicle with a gross vehicle weight above 3.5 tonnes pays, as does any combination in which the motor vehicle itself is above 3.5 tonnes, and every bus whatever its weight. That is the wording of art. 13 ust. 1 pkt 3 of the Public Roads Act (ustawa o drogach publicznych) in force since 21 September 2026. The toll is collected by the Head of the National Revenue Administration (Szef KAS) through the System Poboru Opłaty Elektronicznej KAS (art. 13hb ust. 1ba and 1bb).

The country of registration plays no part. The duty to register rests on the owner, holder or user of the vehicle (art. 13ia ust. 1), so on the Ukrainian company itself, not on a Polish forwarder or customer.

For the rate, the weight is counted together with the trailer or semi-trailer. A 7.5 t van towing a 6 t trailer pays as a vehicle of 12 t or more, because together they reach 13.5 t.

Does a 3.5 t van towing a trailer, 5 t in total, pay e-TOLL? No, not since 21 September 2026. The amendment published as Dz.U. 2026 poz. 982 left only combinations built on a motor vehicle above 3.5 t inside e-TOLL. Unused funds for such vehicles are refunded on a request filed within 6 months of 21.09.2026 (art. 12 of the amendment).

Which roads are tolled and where the first section starts after the border

The e-TOLL network covers about 5,870 km of roads run by the national roads authority GDDKiA, and about 645 km were added on 1 February 2026 (etoll.gov.pl, notice of 19.01.2026). The list of sections is set by a Council of Ministers regulation, last amended on 8 January 2026 (Dz.U. 2026 poz. 33).

For a truck from Ukraine the first tolled section can begin just after the border. According to the list in that regulation, the following sections near the Ukrainian crossings are among those tolled.

The A4 between the Murckowska and Balice I junctions, meaning between Katowice and Kraków, is not on the e-TOLL list. It is a concession motorway where the concessionaire collects the toll (art. 37a ust. 1a pkt 3 of the Paid Motorways Act). The exact route is priced by the official network calculator on etoll.gov.pl, and it is worth running a real route through it before the first trip.

How much an e-TOLL kilometre costs

The rate depends on three things: the road class, the vehicle's weight with its trailer and the Euro emission class. The rates below, in złoty per kilometre, apply from 1 February 2026 (annexes 3 and 4 to the regulation Dz.U. 2026 poz. 33). Class A and S are motorways and expressways, class GP and G are other national roads.

A hundred motorway kilometres for a Euro 6 tractor with a semi-trailer cost 56 zł, about 646 hryvnias. The same hundred kilometres on a national road cost 42 zł, about 485 hryvnias. The billing document is a debit note, not a VAT invoice, because the electronic toll is a public levy (etoll.gov.pl FAQ).

An Euro class that is not backed by a document costs more than any routing mistake. When data affecting the rate are not confirmed by documents, the Head of KAS removes the weight and emission class from the register, and the system charges the highest rate (art. 13ia ust. 11 and 12). For a tractor of 12 t or more on a motorway that means 1.07 zł instead of 0.56 zł per kilometre, almost double. An objection can be lodged within 14 days of the notice (art. 13ia ust. 14).

How a Ukrainian company registers for e-TOLL

Registration has to be done before the first trip on a tolled road. There are three routes: online in the Internetowe Konto Klienta (IKK, the customer account), at a Miejsce Obsługi Klienta (MOK, a customer service point) or through a fuel card issuer. A foreign user signs in to IKK at login.mf.gov.pl with an e-mail address and a password, without any Polish electronic identity (etoll.gov.pl FAQ). Fleet cards integrated with e-TOLL are issued by, among others, Orlen, E100, AutoPay, DKV, EuroWAG, AS24 and UTA.

The statute lists what the company enters in the register (art. 13ia ust. 5): name and address, an identification number, and for each vehicle the registration number, gross weight and emission class, plus the payment mode. The identifier may be the number used in the country of establishment, so a Ukrainian company enters its EDRPOU code and does not need a Polish tax number.

A Ukrainian truck is not in the Polish central vehicle register, so scans of the documents confirming its data must be attached at registration (art. 13ia ust. 6 and 7). Leaving them out risks a 1,000 zł penalty (art. 13k ust. 2c).

The registration itself takes four steps in IKK (etoll.gov.pl, «Registration for companies»).

1. 1Sign in at login.mf.gov.pl and choose the entity type, a company.
2. 2Create a billing account and choose prepaid, deferred payment or a fleet card.
3. 3Add the vehicle: registration number, the last 6 digits of the VIN, a document showing weight and Euro class, and a power of attorney if someone other than the owner registers.
4. 4Create the device using its business number, link it to the vehicle and activate it.

Each registered device receives a reference number (art. 13ia ust. 8). The company adds the vehicle category and that number to the register and then passes the number to the driver (art. 13ib ust. 1 and 3). A driver without the number must refuse the journey (art. 13ib ust. 4), which is why registration belongs in the office before the trip, not at the border.

Data must be updated before a journey starts, for example when a heavier trailer is coupled, and failing to update costs 1,000 zł (art. 13ia ust. 10, art. 13k ust. 2d). The e-TOLL hotline +48 22 460 59 77 answers in Polish, English and Russian, on working days from 6:00 to 22:00 and at weekends from 8:00 to 18:00.

What transmits the position, a phone, an OBU or a ZSL

The statute allows three kinds of device: a mobile device with software, an external locating system and an on-board unit (art. 13i ust. 3a). The phone software is provided free of charge by the Head of KAS (art. 13i ust. 3d).

Linking a device to a vehicle is not enough. An inactive device records no journeys and charges no toll, so to an inspector the truck is driving unpaid (etoll.gov.pl, 21.07.2026).

Reinstalling the app produces a new business number, which has to be linked to the vehicle in IKK again. A device can move between tractor units, but before the journey it must be relinked and activated on the new vehicle.

Prepaid or deferred payment

The law knows two modes: przedpłata, payment in advance, and płatność okresowa z zabezpieczeniem, monthly payment against a security (§ 2 of the Minister of Finance regulation Dz.U. 2022 poz. 2656).

How prepaid works

The balance is topped up before departure with enough for the whole planned journey, and with at least 20 zł when the account opens (§ 2 pkt 1). In the app the minimum top-up for a heavy vehicle is 120 zł, about 1,385 hryvnias (etoll.gov.pl FAQ). Payment is by bank card, fleet card, BLIK or PayByLink, in cash at a customer service point or by bank transfer.

A bank transfer is credited to the billing account within 3 working days of arrival (§ 7 ust. 2). Money sent on Friday evening may not yet be usable at the border on Saturday, so before a trip the balance is topped up by card or BLIK. The automatic top-up feature refills the balance from a card once it falls to a set minimum (etoll.gov.pl, 12.05.2026).

If the money runs out on the road, there are three days. No penalty is imposed when the geolocation data reached the system and the toll was paid within 3 days of the end of the journey (art. 13k ust. 8a). This relief does not apply when the truck is stopped for a roadside check: the penalty is then 1,500 zł, and a later top-up no longer counts as payment (art. 13k ust. 8b).

How deferred payment works and how much security

Deferred payment suits a company with several trucks running through Poland regularly. The monthly debit note arrives within 7 working days after the month ends (§ 8 ust. 2) and must be paid within 14 days of issue (etoll.gov.pl).

The security may be cash, a bank or insurance guarantee, or a surety from an entity rated at least BBB+ or Baa1, and a guarantee or surety must run for at least a year (§ 4 ust. 2 and 4). The minimum amount follows the formula in § 4 ust. 5: Z = S × R × 1.3. Here S is the kilometres on tolled roads over 45 days, no fewer than 2,000, and R is the per-kilometre rate for that vehicle.

For one Euro 6 tractor of 12 t or more, with the minimum 2,000 km and the motorway rate of 0.56 zł, that gives 2,000 × 0.56 × 1.3 = 1,456 zł, about 16,802 hryvnias. The official security amount calculator does the same sum for several vehicle groups at once. After the rate increase of 1 February 2026 the security is worth recalculating.

Once the amount owed reaches 99 % of the security, deferred mode closes and the account becomes prepaid with a zero balance (§ 8 ust. 6 pkt 2). A truck on the road at that moment carries on with no money on its balance. Unused funds are refunded on a written request in IKK or at a customer service point, by the same method they were paid, within 30 working days of the request being accepted (§ 12).

What happens at the border and during a check

e-TOLL has no barriers. Payment is checked by fixed gantries over the road, mobile devices in inspection vehicles and roadside checks by the road transport inspectorate (ITD) and the customs and tax service (art. 13l). The penalty is imposed by decision of the Chief Inspector of Road Transport (GITD), even when the breach was found by a customs officer (art. 13l ust. 1c).

For a carrier from Ukraine a roadside deposit applies. Where the country of establishment has no agreement with Poland on mutual recovery of claims, the inspector collects on the spot a deposit equal to the expected penalty, in cash, by card or by transfer (art. 13m ust. 2 and 3). Without the deposit the truck goes to a guarded car park at the carrier's cost, and 30 days after the decision becomes final, enforcement against movable property begins (art. 13m ust. 7 and 10). Recovering such a deposit is covered in the article on RMPD and SENT deposits.

The same breach can be penalised for one vehicle no more than once per calendar day, from 0:00 to 24:00 (art. 13k ust. 6 and 7). Proceedings cannot start once 9 months have passed since the breach (art. 13n ust. 1).

What to do when the device has been silent for 15 minutes

In e-TOLL, silence longer than 15 minutes obliges the driver to stop at once at the nearest car park or lay-by, or to leave the tolled road (art. 13ic ust. 1). The journey may continue once the signal is back.

If the device is broken, the journey can continue without it. In IKK the user chooses the option to complete a journey, gives the point where transmission stopped, the destination and the time, and on a prepaid account pays for the route in advance (art. 13ic ust. 1a pkt 1 and ust. 1b). Carriage of live animals, medicines, ADR loads with orange plates and a few other special journeys may be declared up to 3 days after the end, provided the goods are not covered by SENT (art. 13ic ust. 1c).

SENT uses a different threshold: an hour before the duty to stop (art. 10c of the SENT act), against 15 minutes in e-TOLL. One phone in the cab can breach both duties at once, and the e-TOLL rule bites first. What to do on the SENT side minute by minute is set out in the article on losing the signal on the road. When the e-TOLL system itself is unavailable, the duty to stop does not apply (art. 13ic ust. 2).

How much e-TOLL penalties cost

e-TOLL penalties are lower than those in RMPD, but there are more kinds of them and some fall on the driver. The amounts below apply from 21 September 2026, after the amendment Dz.U. 2026 poz. 982 removed the reduced rates for cars with trailers. Exchange rate of the National Bank of Ukraine, 11.5401 hryvnias per zł on 23.10.2026.

The driver is the one who enters the category in the device, so the driver pays the 750 zł, and the owner is not penalised again for the same underpayment (art. 13k ust. 5 and 8).

A GITD decision cannot be appealed to a higher authority, because the Chief Inspector is a central government body (art. 53 ust. 1 of the Road Transport Act). Instead, the carrier files a request for reconsideration with GITD itself within 14 days of service of the decision (art. 5 § 2 pkt 4, art. 127 § 3 and art. 129 § 2 of the Code of Administrative Procedure). The duty to pay a penalty expires 5 years after the end of the year in which it was due (art. 40d ust. 3).

What EETS is and whether you need it

EETS, the European Electronic Toll Service, offers one contract, one on-board unit and one account for tolled roads in several countries. In the e-TOLL area it is provided by Telepass since 17 October 2022 and Toll4Europe since 1 August 2024, each only on the sections where it passed accreditation (etoll.gov.pl, EETS section).

An EETS user does not register in the e-TOLL register (art. 13ia ust. 1) and takes billing questions to the provider. The toll amount and the consequences of non-payment are the same as in e-TOLL, and penalties for breaches are imposed on the EETS user (art. 13k ust. 2e, 2f and 5a).

If a truck runs only to Poland, an e-TOLL registration with a phone or an OBU is enough. EETS solves a different problem: one device for several countries with electronic tolling.

How e-TOLL relates to SENT GEO and RMPD

e-TOLL and SENT GEO use the same app and the same business number, but there are two links. For the toll the number is linked to the vehicle in IKK, and for SENT or RMPD it is linked to the filing on PUESC through an option in the app (etoll.gov.pl FAQ). Without the first there is no payment, and without the second the SENT registry sees no position.

The difference in amounts shows which mistake costs more. An unpaid e-TOLL trip costs the owner 1,500 zł, while a missing position in a carriage under RMPD costs 10,000 zł, about 115,401 hryvnias (annex 3 item 3.2b of the Road Transport Act). How to link the phone to the filing and why the list in the app is empty is covered in the article on e-TOLL and RMPD.

The weight thresholds also differ. e-TOLL starts above 3.5 t gross weight, while RMPD has its own limits, discussed in the article on RMPD for a van under 3.5 tonnes. The requirements for SENT locators themselves are gathered in the article on SENT-GEO requirements.

What to do

1. 1Register the company in IKK at login.mf.gov.pl before the first trip, not at the border.
2. 2Add each tractor unit with scans of its registration certificate and Euro class document, so the system does not charge the highest rate.
3. 3Choose a device, create it in IKK by its business number, link it to the vehicle and activate it.
4. 4Give the driver the device's reference number before departure.
5. 5Top up the prepaid balance by card or BLIK before the trip, or work out the security with the formula 2,000 km × rate × 1.3.
6. 6Check the route in the network calculator on etoll.gov.pl, especially the first section after the border.
7. 7Link the same app to the filing on PUESC as well, if the truck travels under RMPD or SENT.

What not to do

• ✗Leaving registration until the border. After Korczowa the A4 is tolled almost at once, and a driver without the number must refuse the journey.
• ✗Topping up by bank transfer on the day of the trip. Crediting can take up to 3 working days.
• ✗Leaving a device inactive after linking it. The journey is not recorded, and to an inspector it is an unpaid trip.
• ✗Reinstalling the app without linking it again. The system does not know the new business number.
• ✗Driving on after 15 minutes of silence. The driver risks a 1,500 zł ticket.
• ✗Assuming a paid e-TOLL trip covers SENT or RMPD. The position reaches the SENT registry only through the link to the filing.

Where our system belongs

Sigil does not register trucks in e-TOLL, top up balances or pay for roads: the e-TOLL account and the security belong to the carrier. Sigil files RMPD notifications with the CMR data carried over one to one after the dispatcher confirms them, and puts the locator number from the vehicle profile into each filing. When the same e-TOLL PL app transmits the position for RMPD, Sigil shows the registry's answers to position queries.

Sigil handles RMPD declarations. The carrier keeps e-TOLL registration, road toll payments and the security in its own e-TOLL account, and Sigil does not file SENT notifications.