Polish Parliament Adopts Act Simplifying Trade in Strategic Goods

On 13 February 2026, the Polish Parliament (Sejm) adopted an amendment aimed at streamlining international trade in goods of strategic importance, including armaments and so-called dual-use items. The key change introduced by the amendment is the digitalisation of procedures and the reduction of paper-based documentation through the implementation of the digital Tracker 2.0 system.

The Act will now be considered by the Senate. If it enters into force in its current form, businesses operating in sectors such as defence, advanced technologies and logistics should experience a tangible acceleration of procedures and greater predictability in the process of obtaining authorisations as well as in maintaining records of strategic goods trade.

What are strategic goods and why does this matter for many businesses?

In practice, this issue is not limited to the defence sector. The category may include, among others:

• armaments and ammunition (including parts, components and accessories),
• dual-use items – that is, technologies and goods that may have both civilian and military applications (for example certain drones, thermal imaging cameras and specific electronic components).

If your company exports, imports, brokers or organises transfers of such goods, the upcoming changes may also affect your operations.

Key changes

Applications and documentation in electronic form

The amendment provides that applications for authorisations and certificates may be submitted electronically, without the need to print documents. Importantly, the entire case workflow- including verification, communication and decision-making- is to take place in one place, namely within the Tracker 2.0 system.

Central register of authorisations and certificates

The Tracker 2.0 system is intended to serve as a central register of, among other things, issued authorisations, import certificates and end-user statements.

Faster access to national general authorisations

For many businesses, this may be one of the most significant operational changes: the waiting period before companies may rely on national general authorisations will be reduced from 30 to 14 days. This is particularly important where a company carries out repetitive and relatively low-risk transactions and seeks to avoid applying for individual authorisations each time.

Shorter document retention period

The new provisions provide for a reduction of the mandatory document retention period related to trade in strategic goods from 10 years to 5 years.

Longer validity of import certificates

Extending the validity period of import certificates effectively provides a longer window for presenting the document to the competent authorities and reduces time pressure in more complex supply chains.

Alignment with EU dual-use regulations and new requirements for firearm marking

The draft legislation also aligns Polish regulations with the EU framework governing controls on, among other things, the export, brokering and transfer of dual-use items.

In addition, the amendment introduces implementing provisions concerning the marking of firearms and their essential components, in particular with regard to the minimum depth of marking, which is relevant for certain entities operating in the firearms or components sector.

When will the changes enter into force?

At this stage, the legislation has been adopted by the Polish Parliament (Sejm) and will now be considered by the Senate. If it subsequently receives approval and is signed by the President, it will enter into force.

It is worth preparing now

If your company trades in strategic goods or dual-use items, we recommend conducting an internal audit to assess your organisation’s readiness to handle strategic goods transactions in electronic form. This may include, for example, organising qualified electronic signatures, preparing standardised documents and template attachments, as well as adapting existing transaction models.

If you would like to assess how the new regulations may affect your transactions or how to prepare your organisation to operate within the Tracker 2.0 system, our experts will be happy to assist with reviewing your procedures, documentation and key regulatory risks related to trade in strategic goods.