You drove abroad — Germany, France, Italy, the UK — and ended up in a crash. The other driver's car is foreign-registered, or the local rules simply don't make sense to you. What now? Which country's law applies? Who do you actually contact? Here's a practical guide for Poles who have an accident abroad.
Disclaimer: This guide is general legal information, not legal advice. How the rules apply depends on the law of the country where the accident happened and on the terms of the insurance policy involved. Where advice or representation is needed, the matter should be assessed by a qualified lawyer in the country of the accident. Twoja Sprawa helps you organise the documents for that assessment.
Step 1: At the scene — what to do
In the first few minutes
- Call the police. In most countries (Germany, France, the UK) this is compulsory once damage exceeds a certain value or anyone is injured.
- Check it's safe — if there's any danger, move the vehicle to the side of the road.
- Take photos — both vehicles, the scene, road signs, any visible skid marks.
- Gather details — the other driver's name, phone number, motor insurance policy number, and vehicle details.
Documents to collect
| Document | Status | Notes |
|---|---|---|
| Driving licence (both parties) | Compulsory | Copy or photograph it |
| Vehicle registration document (both parties) | Compulsory | Front and back |
| Motor insurance policy (other driver) | Essential | Policy number, insurer, expiry date |
| Green Card (proof of cover abroad) | If available | International insurance document |
| Police report | If issued | Case reference and incident details |
| Witnesses | Recommended | Name, phone number, what they saw |
| Photographs | Recommended | Vehicles, damage, the scene |
Reporting to the police
Important: in most European countries you must report the accident to the police within 24–48 hours. Delay can make the claim harder to pursue.
Step 2: Which country's law applies?
Rome II Regulation, Article 4
For a road traffic accident, the applicable law is generally the law of the country where the accident occurred (lex loci delicti — the law of the place of the event).
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In practice: - Accident in Germany → German law (BGB, VVG). - Accident in France → French law (Code Civil). - Accident in the UK → English/UK law (tort law, motor insurance rules). - Accident in Poland, foreign driver at fault → Polish law (Civil Code, Article 436).
What that means for you
- Liability is assessed under local rules — typically fault-based liability in common-law countries, or strict/risk-based liability in many continental European systems.
- Reporting deadlines, required documents, and payout timescales are governed by local insurance law.
- The level of compensation is assessed by local courts or claims handlers — figures can differ significantly from what you'd expect in Poland.
Step 3: The Green Card system — an international framework
What is a Green Card?
The Green Card is an international certificate of motor insurance confirming that your Polish policy is valid abroad. It allows claims to be processed quickly even when the other vehicle is foreign-registered.
Do you have one?
- If your policy was issued in Poland, it should always include Green Card cover — check it's included in your documents.
- If the accident happened within the EU, it should apply automatically.
- If it happened outside the EU (e.g. Turkey, Morocco), ⚠️ check first whether that country is covered.
How to use it when reporting a claim
- Note down the details on the card — policy number, country of insurance (Poland = PL).
- Ask the other driver for their Green Card details, if they have one.
- Report the claim to the relevant National Bureau — see below.
Step 4: The National Bureau system — who actually pays?
How the National Bureaus work
Every country (e.g. Germany, France, the UK) has a National Bureau of motor insurers responsible for settling claims where: - The at-fault vehicle is registered in that country. - The at-fault driver's insurer is refusing to pay, or is unidentified.
For Poland: the Polskie Biuro Ubezpieczycieli Komunikacyjnych (PBUK — Polish Motor Insurers' Bureau) is the National Bureau.
The process
- You report the claim to PBUK (if the at-fault driver is Polish but the accident happened abroad).
- The National Bureau in the country of the accident deals directly with your insurer.
- Your own insurer pays out your compensation.
- The two bureaus settle the matter between themselves (recharge/subrogation).
Contact details for PBUK
⚠️ PBUK is the body operating under Article 98 of the Polish Compulsory Insurance Act. Contact points: - Website: https://ptu.gov.pl (superseding the older PBUK contact details — check for current structures) - Alternative: you can also contact the Insurance Guarantee Fund (UFG) via https://www.uokik.gov.pl
Step 5: How and where to report the claim
Option A: Report to your own insurer (recommended in most cases)
- Call your insurer's helpline (usually available 24/7).
- Explain: "I've had an accident abroad — I need the cross-border claims procedure."
- Send the documents: photographs, police report, the other driver's details, their insurance policy.
- Your insurer will contact the relevant National Bureau and handle the settlement on your behalf.
Option B: Contacting the other driver's insurer directly (if you have their details)
- Generally more complicated — different procedures and a language barrier.
- It's usually better to go through your own insurer.
Step 6: Documents you'll need
| Document | Where to get it | Status |
|---|---|---|
| Police report | Police station in the country where the accident happened | Compulsory |
| Photographs of the vehicle | Your own / provided to insurer | Compulsory |
| Other driver's motor policy | From the other driver | Compulsory |
| Vehicle registration documents | From the other driver | Compulsory |
| Your Green Card | Your motor policy (send a copy) | Recommended |
| Medical certificate | Hospital / clinic in the country of the accident | If injured |
| Repair estimate | Garage in the country of the accident | If there's vehicle damage |
| Translation of documents | Sworn/certified translator (if documents aren't in English) | May be required |
Step 7: Country-by-country differences
⚠️ Note: every country has its own procedure. Here are the key differences:
Germany (BGB, VVG)
- Law: fault-based liability.
- Procedure: report to the insurer within a week, with documents to follow within 2 weeks.
- Payout timescale: 30 days from receipt of complete documentation (similar to Poland).
- Note: the German system is fast, but requires a complete documentation set.
France (Code Civil, Law No. 85-677)
- Law: fault-based liability (more strictly applied).
- Procedure: report to the other driver's insurer within 6 months.
- Payout timescale: up to 3 months from the date of the claim.
- Note: court-appointed experts have significant influence and can reduce compensation by up to 30%.
UK (tort law, post-Brexit ⚠️)
- Law: the tort of negligence — you must prove the other driver was at fault.
- Procedure: report to the at-fault driver's insurer or to your own.
- Payout timescale: up to 30 days once liability is agreed.
- Note: post-Brexit procedures have become more complex — you may need UK-based legal representation.
Italy (Codice Civile)
- Law: a mixed model (fault plus surrounding circumstances).
- Procedure: report within 3 months.
- Payout timescale: up to 90 days.
- Note: pre-litigation mediation (conciliazione) is sometimes required before proceeding further.
Step 8: Deadlines for notifying your insurer
| Country | Deadline |
|---|---|
| Germany | 1 week (without delay) |
| France | 6 months |
| UK | 30 days (typically) |
| Italy | 3 months |
| Poland | Without delay |
Important: always report the accident as soon as possible, even if you don't yet have all the documents. Delay can make the claim harder to progress.
FAQ
Can I sue the at-fault driver if their insurer refuses to pay? Yes. The law of the country where the accident happened allows you to bring a claim before the local courts. In practice, though, it's usually more efficient to work through your insurer or the National Bureau system first.
How long does a cross-border claim take to settle? Typically 1–3 months — faster than going to court, but slower than a domestic Polish claim. It depends on the country and the complexity of the case.
Can I have legal representation abroad? Yes. For larger claims (above EUR 10,000), it's worth instructing a local lawyer. Costs typically range from EUR 1,000–3,000.
What if the at-fault driver's insurer doesn't hold Green Card cover? In that case, the National Bureau in your own country can issue a guarantee and settle matters directly with the at-fault driver's insurer.
Will the compensation be the same as it would be in Poland? No. Each country applies its own standards. Compensation for pain and suffering can be higher (UK, Germany) or lower (France, Italy) than in Poland.
What if the at-fault vehicle is registered outside the EU? ⚠️ The process is more complicated. You may be able to claim through the Insurance Guarantee Fund (UFG) if the at-fault party doesn't respond, but it's generally best to instruct a local lawyer in that case.
Links and resources
- Your own insurer — 24/7 helpline (always call them first).
- PBUK / UFG: https://www.uokik.gov.pl — cross-border claims procedures (in Polish).
- Green Card Bureau info: https://ptu.gov.pl (successor to the older PBUK structure, in Polish).
- National Bureau of the country of the accident — check that country's insurers' or courts' website.
- Financial Ombudsman (Rzecznik Finansowy): https://rf.gov.pl — if your insurer isn't paying out (in Polish).
Summary
An accident abroad is stressful, but the procedures are standardised across Europe. The key steps are:
- At the scene: call the police, gather everyone's details.
- Once you're home: report the claim to your own insurer — not to the at-fault driver's insurer.
- While you wait: your insurer liaises with the relevant National Bureau on your behalf.
- Keep records: everything — photographs, receipts, invoices.
Don't wait — the sooner you report the claim, the better. The international system works, but it does take time.
Final disclaimer: This guide is for general information only. If your claim is substantial or complications arise (the other driver fled the scene, multiple injuries), consider consulting a local lawyer or our partner in the country where the accident happened.
Last checked: 27 June 2026.