Poland is the last EU country without road-toll reform rules

Poland is now the only one of the 27 member states with no national measure notified for the EU's 2022 road-charging directive, more than two and a half years after the deadline. Brussels issued a reasoned opinion against Warsaw in December 2024. The government's bill has still not reached the Sejm.

This is PoliData's monthly reading of the EUR-Lex national implementing measures for Poland, the Netherlands and Germany, checked against the Commission's infringement decisions and each country's legislative record as of 14 October 2026. By that measure Poland has nine directives overdue with nothing notified, the Netherlands four and Germany two. Not every gap matters equally, and two are probably not gaps at all.

Road tolls: Poland stands alone

Directive (EU) 2022/362 extends the EU's tolling and vignette rules to cars, vans, buses and coaches. It also requires heavy-vehicle tolls to vary with CO2 emissions and adds a charge for the external cost of air pollution. The transposition deadline was 25 March 2024. Twenty-six member states have notified measures; Poland has not.

The Commission sent Poland a letter of formal notice in May 2024 and a reasoned opinion on 16 December 2024 (INFR(2024)0169). That is the last step before a referral to the Court of Justice. Italy, which received a reasoned opinion in the same round, was referred to the Court in October 2025 with a request for financial penalties.

The Ministry of Infrastructure's draft amending the public roads act (UC74) would add CO2 and air-pollution charges to the e-TOLL system. The government's work plan aimed for cabinet adoption in the third quarter of 2026; as of 14 October no government bill had been filed in the Sejm. Hauliers running through Poland should expect e-TOLL charges to change once it is adopted.

Corporate sustainability reporting: Berlin and The Hague stalled

Germany and the Netherlands are among five member states with no national measure for the Corporate Sustainability Reporting Directive (CSRD), due on 6 July 2024. Both received letters of formal notice in September 2024. Neither has had a reasoned opinion.

Germany's implementing bill (Drucksache 21/1857) had its first reading on 9 October 2025 and has been in committee ever since. The same bill also transposes the 2025 "stop-the-clock" directive that delayed CSRD reporting, so both of Germany's overdue directives depend on it. The Dutch bill, the Wet implementatie richtlijn duurzaamheidsrapportering (Kamerstuk 36 678), was put on hold in February 2026 pending another amending memorandum. None had been filed by 14 October. Because the law was not in force by 1 October, the finance minister's repair clause now treats voluntary CSRD reporting as compliant through the 2026 financial year.

The stakes have also shrunk. Omnibus I, in force since 18 March 2026, limits the CSRD to companies with more than 1,000 employees and more than €450 million in net turnover, and deletes the listed-SME wave. Member states have until 19 March 2027 to transpose it. For German and Dutch compliance teams, the likely outcome is one national law that implements the CSRD and Omnibus I together, applying to far fewer companies than the 2022 text did.

Anti-money laundering: Poland misses two deadlines

The sixth anti-money-laundering directive, Directive (EU) 2024/1640, is phased. Access to beneficial-ownership registers for people with a legitimate interest was due by 10 July 2025, and the register-access procedures by 10 July 2026. The bulk of the directive is due by 10 July 2027, and a single access point for real-estate data by 10 July 2029. Poland has notified nothing.

The Commission sent Poland letters of formal notice on 25 September 2025 and again on 25 September 2026. The government's bill (print 3163) had its first reading on 9 October and is with the Public Finance Committee. As drafted, its beneficial-ownership register provisions take effect only on 1 October 2027, more than a year after the second deadline. Obliged entities, from banks to notaries, should plan on the current Polish register rules for another year.

The rest of the list

Poland's other overdue directives are narrower. They include Directive (EU) 2023/1438, which updates the protocols national offices use to test agricultural and vegetable plant varieties and was due by the end of 2023. EUR-Lex shows nothing from Poland, but the Commission's January 2024 letters on that directive went to four other states and not to Poland.

The same applies to the Netherlands and Directive (EU) 2023/175, which added the solvent 2-methyloxolane to the EU list of extraction solvents for food. Dutch rules refer directly to the EU annex, so the addition probably applied without a new measure, and the Commission's March 2025 letters did not include the Netherlands. The remaining Dutch entry is the 2024 delegated directive on the machine-readable zone of the EU emergency travel document.

What to watch

• 4 November 2026: the Sejm Public Finance Committee's deadline to report on Poland's AML bill.
• Commission infringement packages: a referral of Poland on road charging would be the next step after the December 2024 reasoned opinion.
• 19 March 2027: the transposition deadline for Omnibus I, the likely vehicle for the German and Dutch CSRD laws.
• 10 July 2027: the main AMLD6 deadline for every member state.

PoliData tracks transposition deadlines and national implementing bills for the EU, Poland, the Netherlands and Germany. See how it works.