Who must register with BDO in 2026 and submit an annual report?

By 15 March, entities on the BDO register must submit an annual report. This deadline sets off a wave of nervous activity every year. Many entrepreneurs only then analyse whether they have kept their waste records correctly. In practice, the problem often starts earlier. A company registers with the BDO in 2025 or 2026, but had already been conducting waste activities before then. However, mere entry in the register will not close the issue. If a business has generated waste, managed waste or marketed packaged products, it must also account for what it was doing prior to registration in the waste database. This means reconstructing the records and submitting outstanding reports, up to five years back. Therefore, the question of who must register with BDO in 2026 has a practical dimension. The financial security of the company depends on the correct answer.

Who must register with BDO 2026 - general rule

The principle is simple. Any entity that carries out waste-related activities should obtain an entry in the BDO before doing so. The scale of the activity is irrelevant. Also occasional activities may give rise to an obligation to register.

In particular, entrepreneurs who:

However, the obligation to register will not apply to a company that generates less waste than the statutory thresholds. Ordinance of the Minister of Climate and Environment of 5 November 2024 lists, among other things, waste such as:

Therefore, if an entrepreneur provides services that result in waste listed in the aforementioned regulation, but in quantities not exceeding the permissible limits, he should analyse whether he qualifies for registration with BDO. Of course, even if he does not produce waste or produces small quantities but still manages it in some way, the obligation to register in the waste database may still apply to him.

Whom the BDO reporting obligation covers

The reporting obligation applies, inter alia, to entities on the BDO register which:

Every registered entrepreneur must submit a report for the previous calendar year by 15 March. This report is based on the waste records kept. However, the biggest risk is for companies that have registered late. An entry obtained in 2026 does not mean that earlier activity is irrelevant. For example, if a company generated waste without registration in 2023 or 2024, it must put its records in order. In practice, this means reconstructing records and preparing outstanding reports.

Moreover, authorities can compare data from different sources. They analyse invoices, contracts, transport documents and contractor data. Therefore, inconsistencies between actual activity and records quickly come to light. As a result, the BDO report becomes the moment to verify the entire history of the company.

Late registration with BDO - why it does not legalise the past

Many entrepreneurs assume that once a BDO number is obtained, the problem with pre-registration data disappears. Meanwhile, the law works differently. Registration has no retroactive effect. Liability for previous actions still exists. If a company placed packaged products on the market without an entry, it has breached the law. If it produced waste and did not keep records, it is also in breach. In such a situation, it is necessary to put the documentation in order and prepare outstanding reports.

It is therefore advisable to carry out an audit of the activity before submitting the first report after registration. It should be established when the obligation to register arose. Then the waste flows need to be reconstructed and the codes checked for correctness. Only then can the report be submitted safely. Doing so minimises the risk of audits and financial penalties.

The most common errors in BDOs that lead to sanctions

Entrepreneurs most often make repetitive mistakes:

Incorrect waste codes are also a common problem. Incorrect classification can change the scope of obligations and necessary documents. In addition, some traders submit „nil” reports, despite the fact that they were actually operating.

The consequences can be severe. The legislator has provided for high administrative penalties, which in extreme cases can reach up to PLN 1 million. Of course, sanctions are graded. However, the authority takes into account the scale of the violation and the degree of culpability.

For this reason, it is worth acting pre-emptively and not only after proceedings have been initiated. About it, how much errors in waste recording can actually cost we wrote in a previous publication. The Waste Act stipulates that a fine is imposed for failure to have the annual waste report submitted by the deadline. The same is true if the transporter does not carry a generated waste transfer card. An operator who reclassifies hazardous waste as non-hazardous in order to reduce the responsibility for its management will also receive a financial penalty under the legislation. Similarly, in the event that it deliberately mixes hazardous waste with neutral waste.

The aforementioned cases, as well as the failure to systematically keep waste records, are a straightforward route to a financial penalty of up to PLN 1 million.

Why BDO's professional service matters

A professional BDO service starts with an audit. First, it is necessary to establish whether and from when the company has carried out waste activities. Then it is verified what obligations realistically arise from this activity. Only then do you sort out the records and prepare a report. In this way, there is no guesswork - only facts are acted upon.

Importantly, late registration with BDO creates a particularly risky scenario. Then simply sending the report correctly „here and now” does not solve the problem. A period of prior activity still needs to be sorted out. This involves reconstructing records and preparing outstanding reports, if required. Otherwise, the company is left with a BDO number, but without a coherent history. The BDO service we offer at Ecologistics24 also has operational value. Firstly, it reduces involvement on the client side. He no longer has to waste time counting or checking. Secondly, it reduces the risk of errors due to the pressure of the 15 March deadline. Thirdly, it gives consistency of documents, which is important for auditing. Finally, it allows the procedure to be built up for years to come, rather than having to „put out the fire” every year.

This is why many entrepreneurs choose the BDO service by Ecologistics24. We relieve the burden on the company and take over the process comprehensively: from verifying obligations and putting documents in order, through record-keeping to the preparation and submission of the report. In addition, we keep an eye on data consistency and support you in correspondence with the authorities if any questions arise. In this way, the entrepreneur does not lose time, does not operate under deadline pressure and reduces the risk of costly errors.

What to do now before 15 March: the secure route for companies

If the 15 March deadline is looming, don't start with the report itself. Start by inspecting the basics. Below you have practical steps to sort out the subject and minimise risk.

If your company is thinking about growth and wants to operate also outside Poland, approach it strategically. In the near future, the European waste transport reporting system will be crucial DIWASS. It is worth taking an early interest, as the obligation to register will extend not only to hauliers, but to all those involved in the international transport of waste.