The main objective of this research work was to study the accuracy of GNSS code receivers under poor sky visibility conditions based on measurements on three different objects (point, line, and surface) and additionally to test results on point positioning with good sky visibility conditions. The measurement was based on 3 smartphones (in the same mode to check repeatability) and 2 handheld receivers (working in GPS+GLONASS modes). The methodology was based on the RTK technique, whose coordinates were assumed as a reference. Based on the results, the significant influence of measuring in the vicinity of high trees on the obtained accuracy was observed for both the precise geodetic equipment and the tested code receivers. More favorable results of point positioning were observed when using mobile phones. On the other hand, in the case of measurement in motion, the handheld receivers guaranteed higher accuracy. Moreover, the study showed that handheld receivers might achieve a better accuracy than smartphones, and that position might be determined with a greater accuracy and reliability. Furthermore, handheld receivers were characterized by a smaller number of outliers.