ADAS Testing in Poland: Vehicle Registration Requirements
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Testing ADAS-equipped vehicles on public roads in Poland can involve more than one legal procedure. The key question is not simply whether a project is described as “ADAS testing”, but how the test vehicle is used, whether the work qualifies as research and development, and what level of driving automation is being tested.
Since 5 July 2026, Polish professional vehicle registration expressly covers entrepreneurs testing vehicles as part of qualifying R&D activity. A foreign-headquartered company can potentially use this route through a branch in Poland. Separately, research involving automated vehicles at Level 3, 4 or 5 on public roads requires a permit from Poland’s National Research Coordinator (KKPB). Testing below Level 3 does not require that additional research permit.
This distinction is particularly important for automotive software companies, OEMs, Tier 1 suppliers and engineering teams carrying out ADAS, infotainment, connectivity, telematics and vehicle-validation projects in Poland.
The short answer: what does an ADAS test vehicle need in Poland?
There is no single “ADAS registration”.
For a company bringing development vehicles to Poland, the correct route depends on the purpose of the vehicle and the functionality being tested.
| Testing scenario | Professional registration | Additional KKPB research permit |
|---|---|---|
| Qualifying R&D road testing with conventional ADAS / automation below Level 3 | Potentially required/applicable | No |
| Automated vehicle research at Level 3 | Applicable to the R&D vehicle | Yes |
| Automated vehicle research at Level 4 or 5 | Applicable to the R&D vehicle | Yes |
| Ordinary company vehicle equipped with production ADAS, not used for qualifying R&D | Normally standard registration rules | No research permit merely because ADAS is fitted |
| Vehicle used only on a closed proving ground and never entering public road traffic | Public-road registration analysis is different | Public-road KKPB permit does not apply until public-road research is conducted |
The important point is that professional vehicle registration and the permit for automated-vehicle research are separate legal layers.
Receiving professional registration does not by itself authorise a Level 3–5 automated-driving research programme on Polish public roads.
Does every ADAS test require an autonomous-vehicle permit?
No.
Polish law now distinguishes six automation levels, from Level 0 to Level 5. Research involving automated vehicles with an automation level below Level 3 is expressly exempt from the special research permit requirement.
This matters because the term “ADAS” covers a very wide range of systems.
A project may involve testing functions such as lane support, automatic emergency braking, adaptive cruise functions, camera or radar perception, driver assistance, sensor fusion or other software without necessarily reaching the legal threshold for Level 3 automation.
The name of the feature alone is not enough to determine the legal classification.
A company should therefore establish the actual automation level of the test configuration before deciding which Polish procedure applies.
Practical example
A development team testing camera perception, lane-support behaviour and braking assistance while the driver remains responsible for supervising the vehicle may be dealing with a Level 1 or Level 2 configuration.
The same vehicle platform configured to allow the driver, under defined conditions, to stop continuously supervising the driving task may move into a different regulatory category.
That difference can change the administrative process substantially.
When is a KKPB permit required?
For research involving a vehicle classified at Level 3, Level 4 or Level 5, public-road testing requires a separate permit.
The permit is issued by the Krajowy Koordynator Prac Badawczych (KKPB) — National Research Coordinator, whose function is performed by the Director of the Motor Transport Institute (Instytut Transportu Samochodowego, ITS).
The new national system became operational in summer 2026 and centralises supervision of automated-vehicle research in Poland.
A permit may cover an area in up to five voivodeships and may be issued for a period of up to three years.
For a company planning a nationwide field-validation programme, this is very different from the previous assumption that each individual test route can simply be handled like an ordinary vehicle journey.
What does a Level 3–5 research application involve?
The KKPB procedure goes considerably beyond vehicle registration.
The organiser must describe the project, the area and roads where research will take place, the vehicles involved, the declared automation level, the purpose and scope of the work and how the research programme will be managed.
The documentation also includes requirements relating to vehicle insurance, technical compliance, safety and risk management.
For example, current rules require an analysis of hazards and risk assessment prepared in accordance with ISO 26262, as well as confirmation that simulation tests and physical trials have already been carried out outside public-road traffic. Research vehicles must also be equipped with an electronic recorder meeting the applicable requirements.
This means that registration should not be treated as the final administrative step after an engineering team has already started planning routes.
For Level 3+ projects, the registration route, vehicle documentation, insurance and research-permit strategy should ideally be considered together.
What is professional vehicle registration?
Professional vehicle registration is a special Polish registration system that allows authorised entities to use vehicles for test drives without permanently registering every development or test vehicle in the ordinary way.
The vehicle is admitted to road traffic using a professional registration certificate and professional registration plates.
Since 5 July 2026, the list of eligible businesses expressly includes an entrepreneur testing vehicles as part of qualifying research and development activity.
This change is particularly relevant to automotive software and engineering companies that previously did not fit neatly into the traditional manufacturer/dealer model.
Can an automotive software company obtain professional registration?
Potentially yes — but being an automotive software company is not enough by itself.
The company must actually be involved in vehicle testing within qualifying research and development activity.
The Polish Road Traffic Act refers here to the definition of R&D contained in the Corporate Income Tax Act. Therefore, eligibility depends on the substance of the project rather than the marketing description of the company.
A company developing and validating a new ADAS function through systematic road testing may have a much stronger basis than a software company that merely uses cars for demonstrations or ordinary business travel.
Before applying, it is worth separating three questions:
- Who is the applicant?
- Does the activity qualify as R&D?
- Are the vehicles genuinely being used for that research activity?
Only after those questions are answered does it make sense to build the registration file.
Can a foreign ADAS or automotive R&D company apply in Poland?
Yes, potentially, but the Polish legal structure matters.
For professional registration, the Act covers an entrepreneur with a registered office in Poland and, where the entrepreneur is headquartered abroad, its branch in Poland engaged in the relevant activity.
For example, a German, Chinese, Korean or US automotive technology company should not assume that its foreign head office can simply request Polish professional plates without examining its Polish structure.
A Polish subsidiary is a separate Polish entrepreneur and its eligibility would need to be assessed independently based on the activity it actually conducts.
This is often one of the first issues that should be resolved before development vehicles are shipped to Poland.
What types of automotive projects can this affect?
The rules can become relevant to real-world vehicle validation involving areas such as ADAS software, camera and radar systems, automated braking, lane-support technologies, navigation, connected-car functions, infotainment, telematics, vehicle-to-infrastructure connectivity, sensor fusion and development-vehicle software validation.
That does not mean every project in these categories qualifies automatically.
A navigation test performed during ordinary use of a production vehicle may have a completely different legal profile from a structured R&D programme involving development hardware, prototype software and documented validation scenarios.
The purpose and technical configuration matter.
Are professional plates the same as Poland’s green EV plates?
No.
This is a common source of confusion for foreign teams.
Professional registration plates in Poland use green characters on a white background.
Registration plates for battery-electric and hydrogen vehicles use dark characters on a green background.
They look different and serve completely different purposes.
A professional plate is connected with the legal status of a test vehicle and the authorised entity conducting test drives. It does not indicate that the vehicle is electric.
Can one set of professional plates be used for different test cars?
Professional registration is designed to support entities operating multiple test vehicles, but the plates are not “universal plates” that can be moved between cars without documentation.
For every vehicle used in road traffic, the appropriate professional registration certificate must be completed and the required vehicle-level formalities must be satisfied.
The system therefore works well for changing R&D fleets, but it still requires controlled documentation for each vehicle.
For an automotive testing operation with multiple development cars arriving and leaving Poland during the year, this can be significantly more practical than performing full permanent registration for every test unit.
A major 2026 change: previously registered vehicles are no longer automatically excluded
This point is easy to miss because many older Polish articles still describe the previous rules.
The amendments that entered into force on 5 July 2026 changed Article 80s and removed the previous structure that effectively limited the system around vehicles not previously registered.
Professional registration can now cover a broader range of qualifying test vehicles, including vehicles being tested within R&D activity.
For international engineering teams moving development vehicles between European test locations, this is a significant practical change.
Older online guides should therefore be checked carefully before being relied on for a 2026 project.
What if the vehicle is used exclusively for R&D?
Polish law now contains a particularly important rule for this situation:
vehicles used exclusively for qualifying research and development activity are subject exclusively to professional registration.
The application framework also requires an R&D entity to declare that vehicles used for the research activity will be used exclusively for research purposes and will not be subject to further resale.
This is not a minor administrative detail.
A company planning to import a development fleet, test the vehicles for several months and then sell them as ordinary used cars should therefore analyse the ownership and disposal model before choosing this route.
What insurance is required for an R&D test vehicle?
Insurance should be addressed before the vehicle enters road traffic.
For professional registration involving R&D, the applicant must declare that it has liability insurance covering its research and development activity.
Separately, motor third-party liability insurance applies to vehicles used in road traffic.
For automated vehicle research, the permit documentation also includes evidence relating to motor liability insurance for the research vehicle.
International companies should therefore avoid treating “insurance” as a single checkbox. The project may involve both the vehicle’s road-traffic insurance and liability associated with the R&D activity.
Can a company use external test drivers?
This is another useful change for companies operating international field-testing programmes.
Where the authorised entity is a vehicle manufacturer or an entrepreneur testing vehicles as part of qualifying R&D, Polish law allows a test drive to be carried out also on the basis of a civil-law contract.
This can matter where the company uses contracted test drivers, freelance validation engineers or external personnel rather than only employees.
The driver still needs the appropriate driving entitlement and all other project requirements remain applicable.
What must a Level 3+ vehicle have before public-road research?
For Level 3–5 automated-vehicle research, the compliance package is significantly broader than professional registration alone.
The organiser is responsible, among other things, for conducting simulation and physical testing before public-road research, maintaining an appropriate risk-management process, protecting the vehicle and systems against unauthorised access and cyber threats, equipping the vehicle with the required recording equipment and ensuring that an appropriately licensed person can control or take control of the vehicle where required.
After the project, the organiser also has reporting obligations to KKPB.
This is why an ADAS project should be classified before the first vehicle arrives, not after the first road test has already taken place.
A practical route for a foreign ADAS testing company
For most international R&D teams, the cleanest approach is:
- Identify the Polish applicant — Polish company, subsidiary or qualifying Polish branch.
- Confirm the R&D basis of the testing activity.
- Classify the automation level of each planned test configuration.
- Determine the vehicle-registration route, including whether professional registration applies.
- For Level 3–5 projects, prepare the KKPB research-permit process alongside the vehicle documentation, safety analysis and insurance.
- Complete the vehicle-level documentation and insurance requirements before public-road testing begins.
This order prevents a common operational problem: engineering, travel and testing schedules being fixed first, with registration and Polish administrative requirements considered only a few days before the vehicles are due on the road.
Example: ADAS field-testing project in Poland
Hypothetical example
A foreign automotive software company establishes a Polish branch and sends six development vehicles to Warsaw for camera, radar and sensor-fusion validation.
The cars will operate in real traffic for several months.
If the tested functions remain below Level 3 and the project qualifies as R&D, the company may need the professional-registration route, but the special KKPB automated-vehicle research permit would not be required solely on the basis of those below-Level-3 functions.
If the project later introduces a Level 3 automated-driving function, the regulatory position changes.
The company would then need to assess the separate KKPB permit requirements before conducting that research on Polish public roads.
The hardware may be the same vehicle.
The software configuration can change the legal procedure.
That is why classification should be done at project level rather than simply by vehicle model.
What are the most common mistakes?
The first is assuming that every vehicle equipped with ADAS is legally an autonomous test vehicle.
It is not.
The second is the opposite: assuming that because a car already has registration plates from another country, no Polish R&D or automated-testing rules need to be checked.
A foreign registration certificate and permission to conduct a specific research programme are different questions.
The third is treating professional registration as the same procedure as the Level 3+ research permit.
It is not.
Finally, foreign companies often examine the vehicle documentation before examining which legal entity will actually conduct the testing in Poland. For professional registration, that corporate structure can be decisive.
How AkcyzaWarszawa can assist automotive R&D companies
AkcyzaWarszawa supports international automotive, engineering and technology companies with Polish vehicle-registration formalities.
For an ADAS or vehicle-testing project, the first stage is typically to identify the correct registration route and review the company structure and vehicle documentation before an application is prepared.
Support can include assessment of professional-registration requirements, preparation and review of registration documentation, representation before the relevant Polish registration authority where legally possible, document translations and coordination of related vehicle-registration formalities.
Where a vehicle does not fit the professional-registration route, the alternative Polish registration or approval procedure can be assessed separately.
For complex Level 3+ automated-driving projects, the vehicle-registration process should also be coordinated with the separate KKPB research-permit requirements.
FAQ: ADAS testing and vehicle registration in Poland
Does ADAS testing in Poland require professional registration?
It depends on the purpose of the vehicle and the entity conducting the testing. Businesses testing vehicles as part of qualifying R&D can fall within Poland’s professional-registration system. Vehicles used exclusively for qualifying R&D are subject exclusively to professional registration.
Does every ADAS test require a permit from KKPB?
No. Research involving automated vehicles below Level 3 does not require the special permit under Article 65l. Level 3, 4 and 5 public-road research does.
Can a foreign company obtain Polish professional test plates?
Potentially yes. Where the entrepreneur is headquartered abroad, the law refers to a branch in Poland carrying out the relevant activity.
Can a software company qualify?
Yes, potentially, if it actually tests vehicles as part of qualifying research and development activity. Simply producing automotive software is not enough on its own.
Do Level 2 ADAS tests need an autonomous vehicle permit?
No, not under the Level 3+ research-permit regime. The law expressly exempts research involving automation levels below Level 3 from that permit requirement. Other vehicle, registration and insurance requirements can still apply.
Does Level 3 testing require a permit?
Yes. Public-road research involving Level 3, 4 or 5 automated vehicles requires a permit issued by KKPB.
Can professional registration replace the Level 3+ permit?
No. Professional registration deals with admitting the test vehicle to road traffic. The KKPB permit authorises the research programme. They are separate procedures.
How long can a KKPB permit be valid?
A permit can be issued for up to three years and may cover an area in no more than five voivodeships.
Can one permit cover several research vehicles?
Yes. The permit framework allows multiple vehicles, and additional or replacement vehicles can in certain circumstances be notified during the permit period under the statutory procedure.
Can contracted test drivers drive professional R&D vehicles?
Potentially yes. For vehicle manufacturers and entities testing vehicles within qualifying R&D, a test drive may also be performed under a civil-law contract.
Can professional plates be used on multiple test vehicles?
Yes, within the professional-registration system and after completing the required documentation for the particular vehicle. They are not unrestricted transferable plates.
Can professional plates be used outside Poland?
International recognition should be checked separately for each country in which testing is planned. A Polish professional registration does not by itself answer every cross-border testing and insurance question.
Are Polish green test plates the same as EV plates?
No. Professional registration plates use green characters on a white background. Polish electric-vehicle plates have a green background.
Before bringing an ADAS test fleet to Poland
If your company plans to carry out real-world ADAS or automated-driving validation in Poland, establish the legal route before scheduling the first public-road test.
The most useful information to prepare is:
the Polish entity conducting the project, the purpose of the R&D work, the number and origin of the vehicles, their current registration status, the intended use of each vehicle and the highest automation level that will be tested.
With those facts, it is usually possible to determine whether the project needs professional registration only or whether the separate Level 3+ research-permit process must also be considered.
Official legal sources
The principal framework is contained in the Polish Road Traffic Act as amended by the Act of 21 November 2025. The provisions extending professional registration for R&D entered into force on 5 July 2026.
Detailed rules for Level 3–5 automated-vehicle research are supported by the Minister of Infrastructure’s regulations of 25 June 2026 and the National Research Coordinator operated by the Motor Transport Institute.
The professional-registration implementing regulation was additionally amended on 20 August 2026, with the amendment entering into force on 26 August 2026.
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