{"id":6036,"date":"2026-03-24T13:35:51","date_gmt":"2026-03-24T12:35:51","guid":{"rendered":"https:\/\/ekopro-grupa.pl\/?p=6036"},"modified":"2026-03-24T13:35:53","modified_gmt":"2026-03-24T12:35:53","slug":"criminal-and-financial-responsibility-for-failure-to-register-with-the-bdo-using-specific-cases-as-an-example","status":"publish","type":"post","link":"https:\/\/ekopro-grupa.pl\/en\/criminal-and-financial-responsibility-for-failure-to-register-with-the-bdo-using-specific-cases-as-an-example\/","title":{"rendered":"Criminal and financial liability for failure to make an entry in the BDO using specific case examples"},"content":{"rendered":"

Criminal and financial liability for failure to register in BDO <\/strong><\/h1>\n\n\n\n
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Failure to register with the BDO is not a minor formal defect that ends in a reminder. If a trader carries out an activity subject to registration and operates without an entry, he or she exposes themselves to real financial liability. Official sources from BDO and Biznes.gov.pl clearly indicate that there is an administrative fine of between PLN 5,000 and PLN 1,000,000 for operating without the required entry in the register. What is more, the sanctions may also apply to \u201eaccompanying\u201d violations, such as failing to include the registration number on documents related to the activity covered by the entry. This is important, as many entrepreneurs mistakenly assume that the lack of an entry is a problem only when the company deals with \u201ebig waste\u201d, while the obligation may also apply to shops, trading companies, waste transporters or entities introducing certain products on the market. <\/p>\n\n\n\n

What are the sanctions for failure to make an entry in the BDO?<\/strong><\/h2>\n\n\n\n

The most severe is the administrative fine. BDO's official materials show a range from PLN 5,000 to PLN 1,000,000 for operating without the required entry in the register, with a separate penalty of PLN 2,000 to PLN 10,000 for transporting waste without the required entry. This shows that financial liability can look different depending on the nature of the breach. At the same time, BDO also indicates sanctions for the lack of a registration number on documents drawn up in connection with the activity covered by the entry. From the entrepreneur's point of view, the most important thing is that the authority does not only assess the fact of waste management itself, but also the formal compliance of the activity with the registration obligation. In practice, this means that a company can be penalised not because it \u201edisposed of waste badly\u201d, but because it operated in the area covered by the BDO without the required entry or without the documents being correctly marked. <\/p>\n\n\n\n

Concrete issues: how do authorities apply these provisions in practice?<\/strong><\/h2>\n\n\n\n
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These are not sanctions only \u201eon paper\u201d. The Public Information Bulletin of the WIO\u015a in Wroc\u0142aw published information about a decision described explicitly as a \u201efine for lack of entry in the BDO\u201d, dated 14 August 2019, confirming that the provincial inspectorates do indeed conduct such proceedings and issue administrative decisions in cases of non-registration. On the other hand, the WIO\u015a in Gda\u0144sk has published an announcement about an administrative fine for transporting waste without the required registration in the BDO register, showing that the registration obligation is also enforced against waste transporters. A broader picture is also provided by NIK: the post-inspection materials indicated that positions on the imposition of fines for the lack of entry in the BDO register were submitted to the provincial inspectors, and in more recent findings, the lack of entry in the BDO register was mentioned as one of the regularly identified irregularities in the area of waste management. These examples are important because they show that the risk does not only apply to large industrial plants, but also to entrepreneurs operating in less obvious areas. <\/p>\n\n\n\n

What can be done to avoid ending up with a penalty and how to mitigate risk once an error is detected?<\/strong><\/h2>\n\n\n\n

The most important thing is to quickly establish whether the activity is actually subject to registration. BDO and Biznes.gov.pl emphasise that the obligation to register applies not only to classic waste producers, but also to many entities introducing products, packaging or offering certain waste-related services. If a company discovers that it is operating without the required registration, it should not wait for an inspection, but should put its formal status in order as soon as possible and verify whether, in addition to the registration itself, there are also any backlogs in records, document marking or reporting. It is also fair to point out that the mere late submission of an application does not automatically guarantee the avoidance of sanctions for an earlier breach. This is why, in practice, an earlier audit of BDO obligations or a quick verification of the company's status following a change in business model, expansion of the offer or launch of new processes works best.<\/p>\n\n\n

\n
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What is the penalty for failure to register in BDO?<\/strong><\/h3>\n
\n\n

There is an administrative fine of between PLN 5,000 and PLN 1,000,000 for operating without the required entry in the BDO register.<\/p>\n\n<\/div>\n<\/div>\n

\n

Are there real examples of such penalties?<\/strong><\/h3>\n
\n\n

Yes. The WIO\u015a in Wroc\u0142aw published information about a decision described as a fine for lack of an entry in the BDO, and the WIO\u015a in Gda\u0144sk informed about a fine for transporting waste without the required entry<\/p>\n\n<\/div>\n<\/div>\n

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Does the absence of a BDO number on the documents also incur a penalty?<\/strong><\/h3>\n
\n\n

Yes. Official BDO material also indicates sanctions for failing to include the registration number on documents produced in connection with the activities covered by the registration.<\/p>\n\n<\/div>\n<\/div>\n

\n

Is the transport of waste without an entry in the BDO penalised separately?<\/strong><\/h3>\n
\n\n

Yes. There is an administrative fine from PLN 2,000 to PLN 10,000 for transporting waste without the required entry.<\/p>\n\n<\/div>\n<\/div>\n

\n

Does subsequent registration with BDO remove the risk of a penalty for an earlier failure to register?<\/strong><\/h3>\n
\n\n

Not automatically. The subsequent rectification of the situation is necessary, but does not in itself mean that the authority will overlook the earlier infringement. This is a practical conclusion arising from the very design of the sanction for operating without the required registration.<\/p>\n\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n\n\n

If you are unsure whether your company should already be listed in BDO or you want to check whether the current entry covers the entire scope of the business, it is worth verifying this before the problem comes to light during an audit. For details, please see Contact<\/a><\/strong> page there, you can describe your situation and match the extent of support to the real risk.<\/p>\n\n\n\n

<\/p>","protected":false},"excerpt":{"rendered":"

Failure to register with the BDO is not a minor formal defect that ends in a reminder. If a trader carries out an activity subject to registration and acts without an entry, he or she exposes themselves to real financial liability. <\/p>","protected":false},"author":2,"featured_media":6037,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_kad_blocks_custom_css":"","_kad_blocks_head_custom_js":"","_kad_blocks_body_custom_js":"","_kad_blocks_footer_custom_js":"","_kadence_starter_templates_imported_post":false,"_kad_post_transparent":"","_kad_post_title":"","_kad_post_layout":"","_kad_post_sidebar_id":"","_kad_post_content_style":"","_kad_post_vertical_padding":"","_kad_post_feature":"","_kad_post_feature_position":"","_kad_post_header":false,"_kad_post_footer":false,"_kad_post_classname":"","footnotes":""},"categories":[4],"tags":[26],"class_list":["post-6036","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-baza-wiedzy","tag-odpowiedzialnosc-karna-i-finansowa-za-brak-wpisu-do-bdo"],"taxonomy_info":{"category":[{"value":4,"label":"Baza wiedzy"}],"post_tag":[{"value":26,"label":"Odpowiedzialno\u015b\u0107 karna i finansowa za brak wpisu do BDO"}]},"featured_image_src_large":["https:\/\/ekopro-grupa.pl\/wp-content\/uploads\/2026\/03\/image-29.png",1024,1024,false],"author_info":{"display_name":"Jakub Nalewa","author_link":"https:\/\/ekopro-grupa.pl\/en\/author\/jakub-nalewa\/"},"comment_info":0,"category_info":[{"term_id":4,"name":"Baza wiedzy","slug":"baza-wiedzy","term_group":0,"term_taxonomy_id":4,"taxonomy":"category","description":"","parent":0,"count":195,"filter":"raw","cat_ID":4,"category_count":195,"category_description":"","cat_name":"Baza wiedzy","category_nicename":"baza-wiedzy","category_parent":0}],"tag_info":[{"term_id":26,"name":"Odpowiedzialno\u015b\u0107 karna i finansowa za brak wpisu do BDO","slug":"odpowiedzialnosc-karna-i-finansowa-za-brak-wpisu-do-bdo","term_group":0,"term_taxonomy_id":26,"taxonomy":"post_tag","description":"","parent":0,"count":1,"filter":"raw"}],"_links":{"self":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6036","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/comments?post=6036"}],"version-history":[{"count":1,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6036\/revisions"}],"predecessor-version":[{"id":6039,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/posts\/6036\/revisions\/6039"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/media\/6037"}],"wp:attachment":[{"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/media?parent=6036"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/categories?post=6036"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/ekopro-grupa.pl\/en\/wp-json\/wp\/v2\/tags?post=6036"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}