Quick reminder: what governs driver posting
For many years, foreign transport companies performing cabotage or international transport in France have had to comply with the rules on posting of workers. These obligations rest on two legal layers:
- EU Directive 96/71/EC (as amended by 2018/957/EU) — general rules on posting of workers in the EU.
- Loi Macron and decree 2016-418 — the French implementation, in particular the obligation to designate a national representative.
In practice, this meant that a Polish carrier sending drivers to France had to submit SIPSI declarations, archive employment documents and maintain a representative on French territory.
What Mobility Package I introduces
Directive (EU) 2020/1057 — part of the Mobility Package I — harmonises the rules on posting of drivers at European level. Key elements:
- A single European declaration system available through the IMI portal (postingdeclaration.eu). Previously each Member State had its own portal (SIPSI in France, MiLoG in Germany, LIMOSA in Belgium, etc.).
- One declaration per driver, regardless of the number of EU countries visited during the mission.
- A copy of the declaration in the vehicle (paper or electronic), in one of the EU's official languages.
- Obligation to record missions in the smart tachograph v2 memory from 1 July 2026.
What still applies — regardless of the portal
The change concerns how declarations are submitted, not the employer's underlying obligations. For each posted driver, the following still apply:
- Minimum wage rates of the host country — in France, the SMIC plus any supplements from the road transport collective agreement.
- A1 certificate issued by the Polish ZUS, confirming that the worker remains affiliated to the Polish social-security system.
- Translation of the employment contract into the official language of the country of inspection (in France: French).
- Mobility Package obligations: vehicle returns every 8 weeks, cabotage limited to 3 operations within 7 days, smart tachograph v2.
- Document archiving — a French inspection can cover a mission performed up to 18 months earlier.
Mixed activity: when a national representative is still required
Loi Macron (decree 2016-418) continues to fully apply to all sectors outside classic road transport:
- Construction (BTP) — BTP card, SIPSI declarations, collective agreement.
- Inter-company posting (B2B) — IT, industry, technical service, consulting, assembly.
- Agriculture, hospitality, events — any service provided to a French client.
This is critical for transport companies with mixed activities. If your team also performs assembly, maintenance or logistics services going beyond classic road transport — these services still fall under Loi Macron and require a national representative.
Concrete examples:
- A driver delivers and installs equipment at the end client → installation = B2B posting.
- A transport company also runs warehouse logistics for a French client → warehousing = B2B posting.
- A driver attends technical training at the client → training = B2B posting.
In each of these cases, it's worth getting the classification reviewed to avoid an administrative mistake.
What to do in your company
Whatever the scale of your French activity, it's worth:
- Reviewing the structure of your missions — does part of your work qualify as B2B posting requiring a representative?
- Checking your archives — French inspections can cover missions up to 18 months back.
- Verifying minimum wages — the French road-transport collective agreement has its own supplement tables.
- Keeping a complete file in the vehicle — A1 certificate, copy of the posting declaration, employment contract translated into French.
Summary
Mobility Package I is primarily an administrative simplification in road transport — a single European portal replaces the national declaration systems. The posting regime itself (minimum wage, certificates, archiving, controls) remains rigorous.
For transport companies with mixed activities — including elements of maintenance, assembly or consulting — Loi Macron and the obligation to appoint a national representative remain fully in force.
If you run a transport company and aren't sure how the Mobility Package affects your French formalities, contact us. We'll review your mission structure and propose a solution covering both transport and any B2B services.
Sources: Directive 2020/1057, Decree 2016-418, European Commission Q&A.
