In June 2025, BALM carried out a nationwide road transport inspection focusing on compliance with cabotage rules, regular weekly rest periods, and the technical condition of vehicles. At 107 checkpoints, 1,715 vehicles were inspected. In the area of cabotage alone, 1,451 checks were conducted, uncovering 58 violations and a total of 139 infractions. Regarding weekly rest periods, inspectors found 78 cases of drivers spending them in their vehicle cabins.
These findings reflect a broader picture revealed by the Federal Motor Transport Authority (KBA) in December 2024. Statistics show that in 2023, out of 5.9 million cabotage journeys conducted in Germany, around 1.8 million lacked declarations – 30% of all operations. These illegal trips covered nearly 581 million km, translating into losses of approximately €870 million for German transport companies. Related documentation issues, such as CHED references, were also noted.
Scale of the problem and blurred responsibility
Despite clear rules – no more than three cabotage operations over seven days and a requirement to report drivers in the Road Transport Declaration Portal – accountability remains diffuse. Under §7c of the German Freight Transport Act (GüKG), carrier, forwarder and client are jointly liable, even if they were unaware of the violation. In practice, however, many supply chain participants shift responsibility to others.
Forwarders complain about not having access to the documents needed to verify the legality of operations. German entrepreneurs note that clients, when asked to check documents on-site, often prefer to hire another forwarder who does not make such demands. Shippers, in turn, expect forwarders to select compliant carriers, though they themselves often lack the expertise to do so.
Insufficient inspections and lack of coordination
Although BALM has increased the number of inspectors to about 800 nationwide, it still lacks the authority to independently check declarations in the IMI system. Such access would, in theory, allow real-time verification. In 2024, BALM inspectors scanned 16 million trucks, but without a legal basis they cannot fully utilise this tool.
The Federal Ministry of Labour (BMAS), responsible for employee posting law, questions the reliability of KBA data, claiming it is based on estimates – a stance disputed by industry organisations.
“It’s unacceptable that the Federal Ministry of Labour is not interested in eliminating large-scale EU law violations on employee posting,” emphasised Dirk Engelhardt, president of BGL. He called for more inspections, better technologies, and more effective cooperation among authorities.
Impact on the market and workers
Illegal cabotage undermines the competitiveness of compliant carriers and, according to the German industry, exacerbates social dumping. Drivers from outside the European Union are carrying out transport operations across Europe for much lower rates than local drivers, giving German clients an undue cost advantage. Analyses estimate the difference in labour costs between a Polish carrier and a medium-sized German company at €380.5 million annually in favour of clients using cheaper labour.
Recent data clearly show that illegal cabotage in Germany is widespread, and the absence of clear accountability maintains the status quo. Despite increased inspections and modern verification tools, the problem persists due to flawed regulations, poor coordination between institutions, and the reluctance of some market participants to verify the legality of transport operations.
According to Article 19 paragraph 2a in conjunction with paragraph 7 of the German Freight Transport Act (GüKG), breaking cabotage rules in Germany is punishable by fines of:
- up to €5,000 for the carrier (€1,000 for a first offence),
- up to €20,000 for the client.
