Examples of Documents Worth Requesting from a Counterparty

“I don’t need to tear any pages out of your passport (…)”

The cult Polish comedy Teddy Bear (Miś) tells the story of Ryszard Ochódzki, who attempts to travel to London using Stanisław Paluch’s passport. The film is, of course, a comedy and still provides plenty of amusement, even to younger viewers born well after Poland’s political transformation.

In real life, however – particularly in the TSL industry – the unauthorised use of another person’s, and more commonly another company’s, documents has quite the opposite effect. Instead of amusement, it often leads to financial loss, fear and a considerable amount of stress.

One of our previous articles, (“Verification of Contact Details Email Addresses and Phone Numbers)”, focused on checking whether we are genuinely communicating with the person or company whose details appear in an email signature or on a freight exchange profile.

To use the Teddy Bear analogy: how can we establish that the person presenting the passport is actually Ryszard Ochódzki rather than Stanisław Paluch? 

Once contact details have been verified and found to be consistent, the next step before entering into cooperation may be to obtain the prospective counterparty’s so-called “company documents.”

Over the years, document forgery has become less common, largely because fraudsters rarely need to alter documents they have managed to obtain. 

Nevertheless, document forgery still occurs, which is why verifying a counterparty’s documents remains a sensible precaution.

What are “company documents”?

The term “company documents” generally refers to documents confirming that a business is legally operating and holds the licences or permits required by law. In the TSL industry, this set of documents also very often includes a copy or scan of the carrier’s liability insurance policy.

Typically, counterparties are required to provide:

• a document confirming that the business is legally registered, for example: 
  • an entry in the Polish Central Register and Information on Economic Activity (CEIDG), 
  • an entry in the National Court Register (KRS); 
• a document confirming authorisation to carry out transport and/or freight forwarding activities, for example: 
  • an authorisation to pursue the occupation of road transport operator, 
  • a Community licence, 
  • a licence to perform road transport activities in the field of freight transport intermediation; 
• a document confirming that the company holds appropriate liability insurance. 

Is there a fixed list of “company documents”?

As a general rule, there is no formal definition specifying exactly which documents should be treated as “company documents” and obtained from a counterparty before cooperation begins.

The list of required documents usually results from:

• the company’s internal verification procedure; 

and/or

• obligations imposed on the freight forwarder or contractual carrier under its insurance policy. 

In addition to the documents listed above, which may be regarded as a reasonable minimum, counterparties may also be asked to provide additional documents, such as:

• proof of payment of the insurance premium or all due instalments under the carrier’s liability insurance policy or the freight forwarder’s liability policy extended to cover contractual carrier liability; 
• a scan of the vehicle or tractor unit registration certificate; 
• a scan of the motor third-party liability insurance policy covering that vehicle; 
• a scan of the trailer or semi-trailer registration certificate; 
• a scan of the motor third-party liability insurance policy covering that vehicle; 
• a scan of a document confirming the right to use the vehicle, such as a leasing authorisation, rental agreement or loan-for-use agreement, where the registered owner of the vehicle is different from the company being verified; 
• a scan of the Certificate of Professional Competence; 
• a scan of the decision assigning the company’s Polish tax identification number (NIP); 
• a scan of the REGON statistical number certificate; 

and many others.

Given the need to act quickly and the limited time available to freight forwarders, a practical solution may be to create a shorter list of documents that should be sufficient for a thorough initial verification of the counterparty.

If verification of these documents – or the information available in official registers – proves insufficient, it may then be reasonable to request additional documents and/or information in order to resolve any outstanding concerns.

What do insurers require?

When providing cover for losses resulting from fraud, insurers impose a number of obligations in their insurance terms and conditions. These requirements are becoming increasingly detailed year by year. The number of obligations is also growing, while the sublimits applicable to fraud-related losses are often being reduced.

Insurers’ requirements most commonly specify:

• which documents the insured party must obtain from the counterparty; 
• how the documents and the counterparty itself should be verified; 
• how, and through which communication channels, correspondence with the counterparty should be conducted. 

In this article, we will focus on the first of these points, i.e. examples of the documents insurers require their policyholders to obtain from counterparties.

TUiR “WARTA” S.A., in §14(6)(1) and (3) of its General Terms and Conditions for Transport Operator Liability Insurance covering road carriers and freight forwarders, requires the insured party to obtain readable copies of documents forming the basis of the company’s business operations, including business registration records or KRS extracts, NIP and REGON details, as well as the relevant permits or licences required by law for transport or forwarding operations.

The insured party is also required to obtain documents confirming that the counterparty holds appropriate carrier’s or freight forwarder’s liability insurance.

UNIQA Towarzystwo Ubezpieczeń S.A., which introduced a separate clause for this type of risk entitled “Release of a Shipment to an Unauthorised Person,” also requires the insured party to obtain readable copies of documents confirming the basis of the company’s operations, including business registration or KRS records, NIP, REGON, an international road transport licence, and the carrier’s liability insurance policy.

STU Ergo Hestia S.A., in special terms offered to one of my clients, required readable copies of documents:

1. authorising the company to carry out road transport of goods or freight transport intermediation in the carrier’s country of establishment. For Polish carriers, these include: 
   • an authorisation to pursue the occupation of road transport operator, subject to the applicable exemptions; 
   • a licence for international road transport; 
   • or a licence for freight transport intermediation; 
2. confirming the existence of a carrier’s road liability insurance policy or contractual road carrier’s liability insurance policy, within the required scope, together with confirmation that the premium or premium instalments have been paid. 

Another of my clients received an insurance offer from Compensa Towarzystwo Ubezpieczeń S.A. Vienna Insurance Group. Under the proposed terms, the policyholder would be required to request and verify licences, permits or concessions held by subcontractors to the extent necessary for the transport activities entrusted to them.

The subcontractors would also need to hold valid road carrier’s liability insurance throughout the entire transport operation. For subcontractors established outside Poland, the insurer required either a policy issued in Polish or a policy certificate available in English. The insurance would have to provide full cover, including theft and robbery risks, cover the relevant type of cargo, and provide an adequate sum insured.

Although insurers are imposing an increasing number of verification requirements, for example regarding checks in the KRS or KREPTD registers, their requirements concerning the actual documents that must be obtained from counterparties still appear to remain at a reasonable and manageable level.

How should the documents be provided?

Ideally, the documents should be sent directly by the counterparty as attachments to an email. Obtaining the documents independently from the carrier’s profile — for example, downloading them from a freight exchange or from the company’s website — is not the best approach. In certain situations, this may prevent you from detecting that the person you are communicating with is impersonating an existing company.

Always request clear and readable scans or photographs so that the documents can be properly inspected visually.

When fraudsters alter a document, it sometimes happens that the forged document is sent in noticeably poorer quality than the other documents. This may be intended to make it more difficult to spot inconsistencies, such as the use of a different font, differences in the background, or other signs of manipulation.

What should happen next?

Once the documents have been obtained, they should be checked carefully. At a minimum, the verification should include:

1. A visual review of each document to determine whether it may have been altered or forged.
   Particular attention should be paid to fonts, whether they are consistent throughout the document, the background, for example whether certain areas are white while others are grey, and the consistency of dates. For instance, a policy providing insurance cover from 1 July 2025 should raise questions if it appears to have been issued in 2024 without a reasonable explanation. 
2. Cross-checking the documents against one another.
   Confirm that all documents contain consistent information, including the company name, address, NIP, REGON and KRS numbers, where applicable. 
3. Comparing the information contained in the documents with information available online.
   This should include checks against official registers such as CEIDG, KRS and KREPTD. 

A thorough review of the documents should help identify potential forgery.

However, the fact that a document is genuine does not mean that the person requesting the transport order is not a fraudster.

Document verification, just like verification of contact details, should therefore be treated as only one of several verification measures that should be carried out before entrusting a shipment to a carrier.

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