Posting declaration (IMI) for road transport drivers: a practical guide for EU carriers
A posting declaration is the form an EU haulier files on postingdeclaration.eu, the public interface connected to IMI, before a driver starts cabotage or cross-trade in another Member State. Article 1(11)(a) of Directive (EU) 2020/1057 requires it "at the latest at the commencement of the posting". One declaration covers one driver, one host country and 1 day to 6 months.
The rules have applied since 2 February 2022 (Article 9 of the directive). Since that date national systems such as SIPSI, MiLoG, LIMOSA or Meldloket are no longer used for drivers within the directive's scope, according to the Commission's Q&A (question 15).
Which operations need a posting declaration?
You need a posting declaration whenever your driver is posted: during cabotage and during cross-trade (the portal calls it "non-bilateral international carriage"). Article 1(7) of the directive says a driver performing cabotage "shall be considered to be posted". Bilateral operations, transit and the bilateral road legs of combined transport are exempt (Article 1(3) to 1(6)).
Bilateral operations come with a margin. On a bilateral goods trip the driver may also perform one loading and/or unloading in the countries crossed, as long as they do not load and unload in the same country. If the outbound trip had no extra activity, the return trip may have up to two. These extra activities stay exempt only for vehicles fitted with smart tachographs (Article 1(3)).
| Route of a truck registered in Poland | What it is | Declaration? |
|---|---|---|
| Poznań to Hamburg, reload in Hamburg, back to Łódź | bilateral | No |
| Poland to Italy through Czechia and Austria, no stops for freight | bilateral plus transit | No |
| Poznań to Madrid with one extra loading in France (smart tachograph) | bilateral plus one extra activity | No |
| Berlin to Munich | cabotage | Yes, Germany |
| Berlin to Paris | cross-trade | Yes, for each country where the operation loads or unloads |
German law shows how the last row works in practice: a trip between two countries other than the employer's home state counts as posting to Germany when either the start or the destination is in Germany (§36(1) AEntG). More routes are in our article on when a posting declaration is not required (in Polish).
Vans changed on 1 July 2026. From that date Regulation (EC) No 561/2006 covers goods vehicles above 2.5 tonnes used "in international transport operations or in cabotage operations" (Article 2(1)(aa), added by Regulation (EU) 2020/1054), so they need a tachograph. The Commission's Q&A (question 9) links the directive's special rules to tachograph data. In our reading, a driver of a 2.5 to 3.5 tonne van doing cabotage or cross-trade is declared through IMI just like a truck driver. The general rules of Directive 96/71/EC may still apply to vans up to 2.5 tonnes and to vans in purely domestic use, so check the host country's requirements for those. The van checklist is in our article on the Mobility Package for vans from July 2026 (in Polish).
How to file on postingdeclaration.eu
Filing takes six steps. Step 1 is done once per user and step 2 once per company; after that you add drivers and file one declaration per driver and host country. The portal works in all 24 official EU languages, and you do not have to use the host country's language, because the authority reads the declaration in its own.
- Create a personal EU Login account. The portal FAQ says every user must have an individual account, and you cannot create a company profile without one.
- Register the company account. A company can have only one account, so check with colleagues first. The FAQ advises at least two users and a functional e-mail address.
- Add drivers, by hand or in bulk with the Excel template in the Driver menu. A driver profile holds identity, address of residence, driving licence number, the start date of the employment contract and the law that governs it.
- Create the declaration: country of posting, start and end date, motor vehicle number plates, goods or passengers, and type of operation (cabotage, international carriage or both).
- Submit it before the first posted operation. The FAQ is explicit that you risk fines if you submit once the driver is already posted.
- Send the copy to the driver. If the driver's e-mail address is in the profile, the portal e-mails the PDF and every amended version automatically.
Article 1(11)(a) of the directive lists seven mandatory items, and the portal will not save a form until all of them are filled in. For larger fleets the portal also exposes an API, documented at api.postingdeclaration.eu, that lets transport software submit declarations with your company's API key. A screen-by-screen walkthrough is in our posting declaration filing guide (in Polish), and login problems are covered in the article on EU Login for the posting portal (in Polish).
Common mistakes
- Putting the trailer plate on the declaration. Only motor vehicle plates belong there, and the FAQ advises against listing a whole fleet, because a long list slows the roadside check.
- Covering several countries with one declaration. The rule is one declaration per driver per host country, and goods and passenger transport need separate declarations too.
- Ticking only international carriage. The FAQ recommends ticking both types, so you do not have to amend the declaration and resend it to the driver if a cabotage job comes up.
- Correcting a name or birth date only in the driver profile. The FAQ says such changes are not reflected in declarations already submitted, so check that driver's live declarations; you may need to withdraw and re-file them.
- Leaving declarations for trips that never happened. A declaration can still trigger a document request, so withdraw it when plans change and keep the tachograph records that show the driver was not there.
Roadside checks, updates and document requests
At a roadside check the inspector may ask for three things only: the copy of the posting declaration, evidence of the transport operations and the tachograph records. That closed list comes from Article 1(11)(b). The Commission confirms in question 20 of its Q&A that control authorities "may not require from a driver at a roadside check other documents". After the posting, the host country can request more through IMI.
The transport evidence is an e-CMR or the documents from Article 8(3) of Regulation (EC) No 1072/2009, and the inspector will look at the country symbols in the tachograph records. The copy can be paper or electronic; the portal's "Scan on the Road" application checks validity from the QR code. Keep the contact person named on the declaration reachable, because the FAQ warns that an inspector may call them. For bilateral drivers, transport evidence and tachograph records are all that may be asked for to prove they are not posted (last subparagraph of Article 1(11)).
A declaration runs for 1 day to 6 months (Article 2(1)(4)(b) of Regulation (EU) 2021/2179). You may extend the end date while the total stays within 6 months; after that you create a new one, and the copy function saves retyping. Article 1(12) of the directive obliges you to keep declarations up to date, so a new truck, a new end date or unplanned cabotage means an edit. Italy sets a hard deadline: updates within five days of the change (Article 12-sexies(3) of Legislative Decree 136/2016).
| Document request after posting | Rule | Source |
|---|---|---|
| What can be requested | transport evidence, tachograph records, pay documents, employment contract, time-sheets, proof of payment | Directive 2020/1057, Art. 1(11)(c) |
| Deadline | 8 weeks from the request; a request for an additional document starts a new 8 weeks | Directive, Art. 1(11)(c); Reg. 2021/2179, Art. 3(2) |
| Period covered | up to 12 months before the request | Reg. 2021/2179, Art. 3(1) |
| No answer | host country may ask your home country for help; that authority must reply within 25 working days | Directive, Art. 1(11)(c) |
| Storage of declarations | 24 months in the IMI repository | Directive, Art. 1(13) |
The portal FAQ adds three practical points: uploads are limited to 4 MB per file, documents need no translation, and every user on the company account gets an e-mail when a request arrives. How to prepare the answer is in our article on document requests after posting (in Polish).
Penalties for a missing or wrong declaration
Each host country sets its own sanctions (Article 5 of the directive), so the same mistake costs very different amounts. In Germany a missing, late or incorrect declaration can cost up to EUR 30,000, in Austria up to EUR 20,000, and in Italy EUR 2,500 to 10,000. The table lists only provisions we checked in national legislation databases:
| Country | Breach | Maximum or fixed penalty | Legal basis |
|---|---|---|---|
| Germany | declaration not filed, incorrect, incomplete or late | up to EUR 30,000 | §23(1) no. 7 and §23(3) AEntG, with §18(2) |
| Austria | declaration or update not filed, late or incomplete; documents not provided to the driver | up to EUR 20,000, one offence regardless of the number of drivers | §26a(1) LSD-BG |
| Austria | driver does not keep the documents | up to EUR 1,000 | §26a(2) LSD-BG |
| Austria | documents not sent via IMI after a request | up to EUR 40,000 | §27a(1) with §12(1) no. 5 LSD-BG |
| Italy | declaration not submitted via IMI | EUR 2,500 to 10,000 | Art. 12-septies(1) D.Lgs. 136/2016 |
| Italy | incomplete, incorrect or not updated declaration | EUR 1,000 to 4,000 | Art. 12-septies(2) D.Lgs. 136/2016 |
| Sweden | posting declaration not shown on request | SEK 60,000 | §45 f Act 1999:678, §9 Ordinance 2022:469 |
Clients carry part of the risk too. The directive requires Member States to sanction consignors and freight forwarders who knew or ought to have known about the breach (Article 5(1)). France, the Netherlands, Belgium and Spain are covered in our article on penalties for a missing posting declaration (in Polish).
Keeping dozens of declarations current costs office time every week. BWT can file posting declarations for your fleet through the portal's official API and, once automatic extension is switched on for your company, extend the ones about to expire.
Frequently asked questions
Is the IMI posting declaration the same as the EU posting declaration?
Yes. "IMI posting declaration", "EU posting declaration" and "road transport posting declaration" all mean the form filed on postingdeclaration.eu, which is connected to the Internal Market Information System (IMI).
Do I need a posting declaration for a trip shorter than a day?
Yes. The portal FAQ says that a posted driver needs a declaration "even for a trip of less than 24h", and the minimum period is one day.
Two drivers share one truck. How many declarations do I file?
Two. The Commission's Q&A (question 17) says each driver in multi-manning needs a separate declaration, even when one of them does not drive in that country.
Can carriers from outside the EU use postingdeclaration.eu?
No. The Commission's Q&A (question 16) says the portal is accessible only to operators established in the EU and the UK, so third-country operators follow each host country's national rules.
Stan prawny: 3 listopada 2026 r. (legal status as of 3 November 2026). Sources: Directive (EU) 2020/1057, Art. 1 and 9; Commission Implementing Regulation (EU) 2021/2179, Art. 2 and 3; Regulation (EC) No 561/2006, Art. 2(1)(aa), as amended by Regulation (EU) 2020/1054; Regulation (EC) No 1072/2009, Art. 8(3); Commission Q&A on posting of drivers, questions 9, 15, 16, 17 and 20; postingdeclaration.eu FAQ; IMI user guide "Road Transport-Posting Declarations" (8 December 2021); AEntG §18, §23 and §36 (Germany); LSD-BG §12, §26a and §27a (Austria); D.Lgs. 136/2016, Art. 12-sexies and 12-septies (Italy); Lag (1999:678) §45 f and Förordning (2022:469) §9 (Sweden).