The aim of this paper is to present a detailed characteristic of possibility of SWOT analysis’ use in the process of strategic planning in small tourist enterprises. The author based conclusions on his own research, but also professional experience, which is a result of his engagement in consultancy for tourist companies. The paper is divided into two main parts. First part is dedicated to critical review of possibilities of SWOT analysis’ use in the process of strategic planning according to literature. In the second part, the author presents his own concept of SWOT analysis, which is based on Delphi technique. Additionally, author’s concept considers an issue of particular circumstances in small tourist enterprises, which determine the application of SWOT analysis.