New WSK Reporting Requirements: Intra-EU Arms Transfers Starting in 2026

On August 3, 2026, the Regulation of the Minister of Foreign Affairs of July 27, 2026 was published, concerning the template for a report on the actual execution of exports or intra-EU transfers of arms from the territory of the Republic of Poland (Journal of Laws of 2026, item 1035). The new regulations will take effect on August 18, 2026, and will introduce a report template adapted to the expanded reporting obligation covering not only the export of arms outside the EU but also intra-EU transfers.

This change is significant for businesses engaged in the trade of arms and should be incorporated into their compliance procedures and internal control systems (ICS).

Intra-EU Arms Transfers – New Reporting Obligations to the Ministry of Foreign Affairs

Until now, Article 27a of the Act on Foreign Trade in Goods, Technologies, and Services of Strategic Importance provided for the obligation to submit an annual report to the Minister of Foreign Affairs regarding arms exports actually carried out. The amendment to the Act of March 13, 2026, extended this obligation to include intra-EU transfers of arms from Polish territory.

This means that a business conducting such exports or transfers must include these transactions in the annual report submitted to the Minister of Foreign Affairs.

The key rules include:

• a broader scope of reporting – the obligation now applies to both actual arms exports and intra-EU transfers from Polish territory;
• annual reporting – the report covers transactions carried out during a given year;
• deadline by the end of April – the report must be submitted to the Minister of Foreign Affairs by the end of April of the following year;
• first report under the expanded rules for 2026 – the transitional provisions of the amendment explicitly state that the report covering the new scope will be submitted for the first time for the year 2026.

In practice, this means that businesses should prepare to report for 2026 by the end of April 2027 at the latest.

Reporting on Arms Exports and Transfers – New Form Effective August 18, 2026

The Regulation of July 27, 2026, implements the amended statutory authorization and introduces a form corresponding to the new scope of the reporting obligation. The previous reporting model was designed for the actual execution of arms exports. The new regulation also covers arms transfers between Poland and other EU member states.

The change may seem primarily technical, but it is of significant importance from a compliance perspective. Data on intra-EU transfers must be identified and collected in a manner that allows for the subsequent accurate preparation of the report.

Failure to comply with the obligation set forth in Article 27a(1) of the Act may result in the arms trade control authority imposing an administrative fine of up to 100,000 PLN.

WSK and Trade Records for Intra-EU Arms Transfers

Businesses engaged in the export or intra-EU transfer of arms should review their current WSK procedures even before preparing the 2026 report.

In particular, it is advisable to:

• identify all intra-EU transfers of arms made from Polish territory in 2026;
• verify whether information regarding these transactions is collected in a manner that allows for its use in preparing the annual report;
• ensure consistency between reported data and licenses, sales records, and transaction documentation;
• update internal WSK instructions, checklists, and the scope of responsibilities for individuals involved in the reporting process;
• include the reporting deadline to the Ministry of Foreign Affairs in the 2027 schedule of obligations.

The extension of reporting to intra-EU transfers is another element of the changes to the Polish system for controlling trade in goods of strategic importance introduced in 2026. For entities operating in the defense sector, this means the need to re-evaluate not only the reporting forms themselves, but also the method of collecting and sharing information within the organization.

Review Your WSK Procedures Before Your First Report Under the New Rules

Defense sector businesses should ensure that their WSK procedures, records, and data collection methods also cover intra-EU transfers of armaments. If necessary, it may be required to update internal documentation, reporting processes, and areas of responsibility.

The Dudkowiak&Putyra Law Firm supports businesses in conducting WSK audits, assessing obligations under regulations governing the trade in goods of strategic importance, and adapting procedures to the new requirements. Contact our team to verify your organization’s readiness for the new reporting obligations.