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Polish Bookmakers Face Probe on Consumer Fairness

By jili tutorial · September 4, 2026

Polish Bookmakers Face Probe on Consumer Fairness

Poland’s consumer-protection authority has launched a preliminary investigation into the product design and terms and conditions of licensed bookmakers. However, legal expert Dr. Justyna Grusza-Głębicka warns that the assessment may be undermined by Poland’s failure to establish clear, sector-specific standards for online platforms. The Office of Competition and Consumer Protection (UOKiK) will examine whether Polish bookmaker websites, apps, and marketing materials contain so-called “dark patterns”—design elements that influence customers to gamble or encourage frequent play for the operator’s commercial benefit. The agency will also scrutinize terms and conditions for any unfair contractual provisions covering the cancellation of bets, suspension of player accounts, and settlement of winnings.

Consumer Protection Authority Investigates Licensed Operators

Led by UOKiK President Tomasz Chróstny, this review marks the first examination of consumer rights since Poland overhauled its online gambling regime in 2017. At that time, the market was significantly tightened, with only seven bookmakers licensed under the new Gambling Act.

Dr. Justyna Grusza-Głębicka, a legal expert in Polish gambling and a representative of the Institute for Gambling Regulation (FIRH), described the intervention as a turning point for the licensed betting sector. “Until now, regulatory scrutiny of licensed gambling operators has been associated primarily with the Gambling Act and the activities of the Ministry of Finance and the National Revenue Administration,” she explained. “UOKiK’s intervention brings the consumer-protection dimension much more clearly into the regulatory discussion.”

Focus on Unfair Terms and Consumer Liabilities

Of particular concern are the liabilities imposed on customers through bookmakers’ terms and conditions. These include the circumstances under which an operator can void a bet, block an account, or withhold the settlement of winnings. If UOKiK establishes that operators have violated Polish consumer law, they could face significant financial penalties.

Expert Warns of Missing Sector-Specific Standards

Grusza-Głębicka emphasized that licensed operators must uphold high standards of consumer protection and responsible gambling. Yet Poland lacks sector-specific rules that detail how broad consumer-protection principles should be applied to individual betting products. “Consumer-protection obligations applicable to online gambling in Poland are fragmented across different areas of law, while detailed sector-specific standards governing the design of digital gambling products remain limited,” she said.

“Operators are already subject to responsible gambling requirements under gambling legislation, as well as general consumer-protection rules,” she added. “However, when we move from general legal principles to very specific questions concerning product architecture, interfaces, player journeys, notifications or other engagement mechanisms, the regulatory boundaries become considerably less clear.”

The investigation will therefore test not only the legal wording of operators’ contracts but also how those provisions are presented and applied throughout the customer journey—from engagement with markets, odds, and offers to pricing and promotional materials.

Dark Patterns or Predictable Standards?

Close attention is needed around the terminology of “dark patterns”—digital design choices that may steer customers toward particular decisions or make actions such as withdrawing, closing an account, or stopping play more difficult. Grusza-Głębicka said that scrutiny of these mechanisms must be accompanied by practical guidance that allows operators to distinguish acceptable engagement tools from manipulative product features.

“If regulators increasingly scrutinise individual elements of product design, the market needs sufficiently clear and predictable guidance on where legitimate customer engagement ends and potentially manipulative or harmful design begins,” she noted. “A high level of consumer protection should be expected from licensed gambling operators, but this should be accompanied by sufficiently clear standards and guidance on what good practice means in practical terms. Enforcement is necessary where infringements occur, but enforcement should not become a substitute for clear and predictable regulation.”

She also cautioned against overreach, particularly regarding gambling advertising on social media or streaming platforms. “This is not how UOKiK describes the proceedings in its official announcement,” Grusza-Głębicka clarified. “The authority refers more broadly to websites, apps, communication with players and the overall design of betting services.”

Competition from Illegal Operators Adds Pressure

FIRH believes the proceedings must also be assessed against the competitive pressures posed by Poland’s unlicensed gambling sector. Grusza-Głębicka warned that illegal operators do not comply with the consumer-protection, responsible-gambling, or advertising standards imposed on licensed businesses. “Consumer-protection policy should therefore consider not only the standards imposed on licensed operators, but also whether consumers are effectively being channelled towards the regulated market where those standards can actually be enforced,” she said.

“For FIRH, these two objectives are not contradictory. Strong consumer protection and a competitive, well-regulated legal market should reinforce each other.”

Call for Clearer Regulation in a Changing Landscape

Grusza-Głębicka concluded that the UOKiK proceedings should prompt a wider review of how Poland regulates the relationship between bookmakers and their customers. “They provide an opportunity for a broader discussion about what modern consumer protection in online gambling should look like, how detailed the applicable standards should be, and how regulators and the industry can create a framework that is both effective for players and predictable for licensed businesses.”