ETS2 and transport companies in Poland – how to prepare for rising transport costs

ETS2 and transport companies in Poland is a topic that will directly affect operating costs, freight rate calculations and the profitability of transport contracts in the coming years. Although road transport companies will generally not purchase emission allowances directly, the ETS2 mechanism may increase fuel prices and, as a result, raise the operating costs of carriers.

For the transport, forwarding and logistics sector in Poland, this is not only a regulatory issue or part of the wider decarbonisation debate. It is primarily a financial challenge. Transport companies will need to analyse their cost per kilometre, route profitability, contract structures, pricing policies and cash flow more precisely.

In practice, ETS2 may become one of the factors accelerating the professionalisation of financial management in the Polish transport sector. Reliable accounting data, ongoing margin analysis and well-prepared management reporting will become particularly important.

What is ETS2 and why does it matter for road transport in Poland?

ETS2 is a separate emissions trading system covering CO₂ emissions from fuel combustion in road transport, buildings and selected additional sectors. Unlike the traditional European Union Emissions Trading System (EU ETS), which mainly applies to industrial installations and the energy sector, ETS2 is designed to operate higher up the fuel supply chain.

This means that the obligation to purchase and surrender emission allowances will apply to entities placing fuels on the market. Transport companies in Poland will feel the impact indirectly, mainly through fuel prices.

For carriers, the three key consequences are:

• higher fuel costs may increase the cost of providing transport services,
• volatility in allowance prices may make long-term freight rate planning more difficult,
• differences in the pace of fleet modernisation across EU countries may affect the competitiveness of transport companies.

According to the current framework, ETS2 is expected to become fully operational in 2028, while monitoring and reporting obligations for regulated entities started earlier. From the perspective of transport companies in Poland, the key issue is that the cost of the system may be passed on through fuel prices.

For entrepreneurs, this means that the time available for preparation is limited. The greatest risk applies to companies operating on low margins, businesses with limited ability to pass costs on to customers, and carriers entering into long-term contracts without effective indexation mechanisms.

Why is ETS2 particularly important for Polish carriers?

Road transport is one of the key segments of the Polish economy. According to the Polish Economic Institute (PIE), transport and storage accounted for approximately 7% of Poland’s GDP in 2024. Road transport is especially important: according to PIE data, it accounted for 87% of freight volume and 81% of freight performance in Poland in the same year. Polish carriers are also strongly present in international transport, including cross-trade and cabotage operations.

This means that changes in fuel costs may affect not only individual companies, but also the competitive position of the entire Polish road transport sector. Three characteristics of the Polish market are particularly important.

First, the sector is highly fragmented. According to the PIE report, in 2023, 84% of road transport companies holding a Community licence operated no more than 10 vehicles. This market structure limits the ability of many companies to quickly finance investment in new vehicles, technologies or charging infrastructure.

Second, Polish road transport remains heavily dependent on diesel. The PIE report indicates that diesel-powered vehicles dominate the structure of heavy goods vehicles in Poland, while the share of zero-emission vehicles remains very low.

Third, many companies operate under strong price pressure. Increases in fuel costs will not always be easy to transfer to customers, especially where contracts do not include effective indexation clauses or where the company competes mainly on price.

ETS2 and cost per kilometre – what should transport companies calculate?

The most important task for a transport company is to determine how fuel price increases may affect the actual cost per kilometre. A general assumption that costs will rise is not enough. The company should know which routes, contracts and customer groups are most sensitive to changes in fuel prices.

The analysis should cover at least:

• average fuel consumption by vehicle type and route type,
• the share of fuel in the total cost of transport,
• profitability of individual contracts,
• the possibility of applying fuel surcharges or indexation mechanisms,
• the impact of fuel price increases on cash flow,
• fleet structure and planned investment expenditure.

Well-managed accounting services in Poland for transport companies should provide data that allows businesses not only to record costs correctly, but also to assess their impact on profitability. In the transport sector, it is particularly important to allocate costs to vehicles, routes, contracts or cost centres.

Without this approach, a company may realise too late that some assignments are no longer profitable. ETS2 will increase the importance of ongoing margin monitoring, because fuel is one of the most important and volatile cost components in road transport.

The impact of ETS2 on transport service prices in Poland

The introduction of ETS2 may lead to higher transport service prices, but the scale of the increase will not be the same for all companies. The impact will depend on the type of transport, route length, customer structure, the carrier’s negotiating position and the contractual framework.

The greatest risk applies to companies that:

• operate long-distance routes with high fuel consumption,
• have low margins and limited financial reserves,
• enter into long-term contracts without rate adjustment mechanisms,
• do not analyse contract profitability at the level of individual customers,
• finance their fleet through leasing and have high fixed monthly liabilities,
• operate in highly competitive market segments.

From a management perspective, it will be crucial to prepare several cost scenarios. A company should check how profitability changes under different fuel price increase assumptions. This approach makes it possible to prepare pricing policies in advance and avoid a situation where the cost increase becomes visible only in financial statements after the accounting period has ended.

In practice, this requires combining accounting, financial controlling and ongoing operational analysis. Accounting data alone is not enough if it is not translated into decisions on rates, routes and contracts.

The importance of ETS2 for sector costs is also confirmed by scenarios analysed in the Polish Economic Institute report. The modelling indicates that, in scenarios including ETS2, transport service prices in Poland could increase by approximately 1.5%, while transport sector activity could be around 0.7–0.8 percentage points lower compared with scenarios without this mechanism. The final scale of the impact will depend on allowance prices, fuel prices, fleet structure and the ability to pass costs on to customers.

Fuel clauses and contract indexation

One of the most important tools for limiting cost risk is a properly drafted fuel clause. In an environment of increasing volatility in transport costs, a transport company should ensure that contracts with customers allow rates to be updated in the event of a significant increase in fuel prices.

A fuel clause should be precise and based on objective indicators. It is worth defining, among other things:

• which fuel price index will be used,
• how often the rate will be updated,
• from what threshold a cost change triggers indexation,
• whether the mechanism works both ways, meaning for both increases and decreases in fuel prices,
• how the change in the service price will be documented.

From a financial perspective, it is also important that indexation rules are consistent with the company’s cost calculation model. If a company does not know the exact share of fuel in the cost of transport, it will be difficult to justify a change in the service price during negotiations with a customer.

In this area, tax advisory in Poland may be helpful, especially where changes in rates, fuel surcharges or adjustments to service remuneration affect documentation, invoicing and tax settlements under Polish tax law.

ETS2 and cash flow in transport companies

Rising fuel prices are not only a higher cost in the profit and loss account. They also create a cash flow challenge. Transport companies often incur the costs of fuel, wages, leasing and road charges before they receive payment from the customer. If fuel costs rise, the demand for working capital may also increase.

Particular risk arises where a company has:

• long payment terms from customers,
• high monthly leasing instalments,
• significant exposure to international transport,
• limited cash reserves,
• little ability to shorten the receivables cycle.

In such conditions, even a profitable contract may create cash flow pressure if operating costs are incurred faster than customer payments are received. For this reason, preparation for ETS2 should include not only margin analysis, but also cash flow forecasting.

Transport companies in Poland should consider preparing financial scenarios that take into account fuel cost increases, different payment terms and possible delays in customer payments. Such forecasts help assess in advance whether it will be necessary to renegotiate commercial terms, increase financing limits or change the pricing policy.

Fleet decarbonisation and investment decisions

ETS2 is intended to support emission reductions, but in practice, rapid electrification of heavy road transport remains difficult. For many Polish carriers, the main barriers are the high cost of zero-emission vehicles, limited charging infrastructure and the specific requirements of long-distance routes.

Not every transport company will be able to quickly replace diesel vehicles with zero-emission vehicles. This applies especially to companies handling international transport, where range, delivery time, charging availability and cost predictability are critical.

At the same time, companies should already analyse which parts of their business are most suitable for gradual fleet modernisation. These may include, in particular:

• local and regional transport,
• fixed routes with a return to base,
• services for customers requiring a reduced carbon footprint,
• segments where vehicles can be charged outside working hours,
• contracts where a higher service price can be justified by ESG requirements.

An investment decision concerning new vehicles should be preceded by an analysis of the total cost of ownership. This should include not only the purchase price or leasing instalment, but also energy costs, service costs, insurance, financing, possible subsidies, expected residual value and the impact on access to transport assignments.

Management accounting is particularly important in this area. A company should compare investment options based on data, not only on technology providers’ declarations or customer expectations.

Management reporting as a preparation tool for ETS2

Many carriers know their costs at a general level, but do not always have access to up-to-date data on the profitability of specific routes, vehicles or customers. In an environment of rising fuel costs, this information becomes critical.

Good management reporting should enable the company to analyse:

• cost per kilometre by vehicle and route type,
• fuel consumption by vehicle and driver,
• margin by contract or customer,
• the share of fuel costs in revenue,
• leasing, service and fleet insurance costs,
• payment terms and the impact of receivables on liquidity,
• differences between planned and actual transport costs.

Such data allows companies to respond faster to market changes. A transport company can renegotiate unprofitable contracts, change its route structure, reduce low-margin assignments or prepare stronger pricing arguments for customers.

Larger transport companies may consider implementing cyclical financial and operational reports. These can include both standard accounting reports and more advanced management reports prepared with analytical tools. In this area, solutions supporting financial and management reporting, such as the Customer BI and Reporting Portal, may be helpful.

ETS2, taxes and accounting in Poland – what should companies pay attention to?

ETS2 should not be treated solely as an environmental issue. Rising fuel costs will affect accounting, taxes, cash flow and financial planning. Transport companies in Poland should pay attention to several areas:

• Correct recording of fuel costs – the greater the price volatility, the more important it becomes to have up-to-date data and the ability to allocate costs to specific vehicles, routes or contracts.
• Value Added Tax (VAT) – higher fuel invoices may increase input VAT, but this does not automatically mean cash-flow neutrality. The company must finance the higher gross expense until the tax is settled and customer payment is received.
• Investment decisions – leasing, vehicle purchases, fleet modernisation, charging infrastructure and possible subsidies require correct accounting and tax treatment.
• Documentation of prices and surcharges – if the company introduces fuel surcharges, changes price lists or applies indexation mechanisms, it should ensure consistency between contracts, invoices and settlement rules.

This is why preparation for ETS2 should involve not only the operational department, but also accounting, finance, legal teams and the people responsible for customer relationships.

How can transport companies in Poland prepare for rising transport costs?

Preparation for ETS2 should begin with organising financial and operational data. A transport company should know which parts of its business generate margin and which are particularly sensitive to fuel price increases.

A practical action plan may include five steps.

1. Analyse current transport costs

The company should determine the actual cost per kilometre for different vehicle types, routes and contracts. The share of fuel in total costs and the impact of fuel price changes on margin are particularly important.

2. Prepare fuel price increase scenarios

It is worth preparing several variants: moderate, increased and high cost growth. This allows the company to check which contracts remain profitable and which require renegotiation.

3. Review customer contracts

The company should check whether its contracts include fuel clauses, indexation mechanisms or the possibility of updating rates. Without such provisions, the company may have to absorb the increase in costs on its own.

4. Assess fleet structure and investment plans

The company should analyse vehicle age, service costs, fuel consumption and fleet modernisation options. A quick purchase of zero-emission vehicles will not always be the best decision, but the lack of an investment plan may increase risk in the following years.

5. Implement management reporting

Ongoing analysis of costs, margins and cash flows allows the company to respond faster to change. In an environment of rising cost pressure, management reporting becomes one of the basic tools for protecting profitability.

The role of accounting and controlling outsourcing for transport companies

The transport sector operates in an environment of high cost volatility. Fuel, wages, leasing, road charges, service costs, insurance and exchange rates affect financial results much faster than in many other industries.

For this reason, accounting support for a transport company should be linked with management analysis. Standard bookkeeping may not be enough if management does not receive the information needed to make business decisions.

Professional support may include:

• bookkeeping and accounting,
• preparation of financial reports,
• cost analysis by vehicle, route or contract,
• support with tax settlements,
• analysis of the impact of fleet investments on profitability and liquidity,
• support with HR and payroll settlements,
• preparation of data for management or a foreign head office.

For companies employing drivers, payroll services in Poland are also particularly important, as labour costs remain one of the key factors affecting transport service prices.

For international companies, consistency of financial reporting between the Polish company and the capital group is also important. This applies especially to businesses handling cross-border transport, operating leased fleets or reporting results to a head office outside Poland.

ETS2 as an impulse to change cost management models

ETS2 is not the only challenge facing the transport sector, but it may reveal problems that were previously less visible. Companies operating on very low margins and without precise cost calculations may struggle to maintain profitability.

Rising fuel costs may accelerate several processes:

• greater pressure to renegotiate rates,
• growing importance of indexation clauses,
• consolidation in parts of the market,
• increased interest in management reporting,
• more cautious investment decisions,
• greater importance of financial data in customer negotiations.

For well-prepared companies, ETS2 may also become an opportunity to improve their management model. Businesses that know their costs, can justify their prices and quickly identify unprofitable contracts will be better prepared to operate under growing regulatory and cost pressure.

Summary

ETS2 and transport companies in Poland should be analysed not only from the perspective of climate regulation, but above all from the perspective of costs, margins and cash flow. Carriers will mainly feel the impact of the system through fuel prices, which may affect cost per kilometre, contract profitability and competitiveness in the European market.

The most important preparatory actions include analysing transport costs, preparing fuel price increase scenarios, reviewing customer contracts, assessing fleet structure and implementing ongoing management reporting. Companies that treat ETS2 only as a distant regulatory obligation may notice its impact on financial results too late.

getsix® supports companies operating in Poland in the areas of accounting, tax, HR and payroll, and financial reporting. For transport companies, it is particularly important to combine correct settlements with practical cost analysis that supports business decisions in an environment of rising cost pressure. Contact us.