New obligations for hauliers in Europe this October: are you ready?

The start of October will be particularly important for companies operating on the Iberian Peninsula and in south-eastern Europe. Romania is replacing the existing vignette model for trucks with charges based on the distance travelled. Spain, meanwhile, is moving control documentation for domestic and cabotage transport into a digital format.

Carriers serving the United Kingdom also need to review their procedures. The ENS filing requirement itself is not new, but British authorities are paying closer attention to the accuracy of the information submitted. After 30 September, errors may lead to enforcement action. In Poland, some companies have only a few days left to complete their self-registration under the National Cybersecurity System rules.

Spain makes digital DeCA mandatory from 5 October

A significant new requirement will take effect in Spain a few days later. From 5 October 2026, the Administrative Control Document, known as DeCA, must be issued in digital form for road freight transport.

The scope of the rule is particularly relevant to foreign operators. DeCA will be required for domestic transport carried out within Spain and for cabotage. It will not apply to international transport simply because a route starts, ends or passes through Spain.

The document must be generated directly in the digital system as a PDF file no larger than 5 megabytes. It must also contain a QR code linking directly to the file stored in a secure repository.

The driver must receive a copy before the journey begins. During an inspection, the document can be shown on a mobile device or as a printed copy containing the QR code. The documentation must be retained for at least one year. Further details on the new document are available in our article on the requirement.

United Kingdom: ENS errors may trigger penalties after 30 September

Carriers transporting goods to the United Kingdom should pay close attention to the accuracy of their Entry Summary Declarations, or ENS filings. British authorities have identified 30 September 2026 as the deadline for reviewing how certain declaration fields are completed and correcting any compliance issues.

This does not introduce a new ENS filing obligation in October. Safety and security declarations are already required before goods enter the United Kingdom. The change concerns how errors will be handled: after 30 September, discrepancies found during inspections may result in further action, including requests to correct the information and customs penalties.

Authorities are focusing in particular on the field identifying the means of transport crossing the border. For accompanied Ro-Ro movements and Eurotunnel crossings, the vehicle registration number must be provided. Common mistakes include entering a generic description such as ‘truck’, using the trailer number or entering both the vehicle and trailer numbers.

If the vehicle changes before reaching the border, the declaration must be updated accordingly. For unaccompanied Ro-Ro shipments, the vessel’s IMO number is required instead.

Errors can also concern the identification of containers and trailers. When a container is carried on a trailer, the unique container number must be entered rather than the trailer’s registration number.

Carriers should therefore review both the information supplied by drivers and business partners and the software used to generate ENS filings. The declaration must be submitted before the goods arrive in the United Kingdom and must contain all required data. The British system also allows amendments to previously submitted declarations.

Responsibility for the filing may rest with a representative or another authorised party, but carriers should ensure that all information needed to prepare the declaration correctly is available and up to date before the vehicle reaches the border.

Poland’s National Cybersecurity System deadline falls on 3 October

In Poland, 3 October 2026 is the deadline for certain businesses to apply for inclusion in the register of essential and important entities under the amended law on the National Cybersecurity System, which implements the European Union’s NIS2 Directive.

The transport sector is not covered as broadly as the wording of the legislation might suggest. The rules refer, among others, to road infrastructure managers and providers of intelligent transport systems, or ITS. A typical road carrier is not automatically subject to the new obligations solely because it operates a transport business.

NIS2 may nevertheless affect the transport, freight-forwarding and logistics sector indirectly. Regulated entities must account for supply-chain security and their relationships with suppliers. In practice, this may lead to additional requirements for business partners, subcontractors and providers of transport management systems, telematics, data-sharing platforms and cloud services.

For entities that already met the relevant criteria when the new rules entered into force, the deadline for implementing the main obligations under the act is 3 April 2027.

Romania switches to the distance-based TollRo system

One of the most significant changes for international road transport will take effect in Romania on 1 October 2026. The existing rovinieta for goods vehicles with a permissible gross weight of more than 3.5 tonnes will be replaced by the TollRo system.

Under the new model, charges will be calculated based on the distance actually travelled. The amount will depend on factors including the distance, vehicle specifications, emissions class and road category. TollRo will apply to goods vehicles weighing more than 3.5 tonnes travelling on Romania’s tolled road network.

The launch remains scheduled for 1 October, but carriers have reported technical problems in the run-up to its introduction and are calling for a transition period during which some penalties would not apply.

Carriers report problems with the new system

UNTRR, Romania’s road transport association, has reported discrepancies between charges calculated for the same route, problems with the application and incomplete integration with equipment and OBU providers.

The association cited the Bascov–Zalău route as an example. During testing, a route ticket cost 144.42 lei, while a live-monitoring session showed a charge of 156.90 lei. The difference was 12.48 lei, or approximately 8.6%. UNTRR also reported cases in which electric vehicles were incorrectly classified during testing.

The industry has raised practical concerns as well. According to UNTRR, issuing a single route ticket can take around five minutes, and some vehicle data must be entered again. For a fleet of 300 trucks, the association estimates that this would require approximately 25 hours of work.

Proposal would suspend some penalties

The problems have also reached the legislative level. A proposal concerning transitional arrangements for TollRo has been submitted to Romania’s Economic and Social Council, known as CES.

One proposed measure would temporarily suspend penalties for failing to pay TollRo in cases involving violations committed between 1 October 2026 and 31 March 2027. UNTRR is also seeking the suspension of the fixed 2,000 lei penalty when the IT system cannot determine the vehicle’s full route.

This would not suspend TollRo itself. Under the association’s proposal, carriers would still pay for the distance that the system can correctly determine and verify.

For now, these are legislative proposals rather than binding rules. Carriers should not assume that a penalty-free period will automatically begin on 1 October.

Minister says no penalties if the system is not operational

Radu Miruță, Romania’s acting transport minister, has also addressed the concerns. On 28 September, he said that if the TollRo platform was not operational on 1 October, he would not sign the order authorising penalties against carriers.

At the same time, the launch date remains in place. The minister said that implementing TollRo is an obligation linked to a contract managed by CNAIR and that postponing the system again could affect funding connected with Romania’s recovery plan.

For carriers, this leaves considerable uncertainty just days before the planned launch. TollRo is due to start operating on 1 October, while proposals concerning penalties are still being processed and the industry continues to report technical problems.

More comprehensive on-board solutions are expected to become available later. VDO Link and OBU 5+ devices distributed by UNTRR, together with interoperability with the European Electronic Toll Service, or EETS, are expected to be available from 15 January 2027.