Regulatory Baseline

The Polish Gambling Act of 19 November 2009, as consolidated and amended through 2025, remains the core legal framework governing gambling in Poland. It maintains:

• online oversight measures (European Economic Area (EEA)-based data localisation/storage, use of a .pl domain, and remote supervisory access);
• a public register of unlawful domains with corresponding ISP/payment blocking for unlicensed operators; and
• tax structures and settlement procedures set directly by the act.

Institutional Oversight

The Department for Gambling Market Regulation and Gambling Tax, operating under the minister competent for public finance, is the central regulatory authority for the gambling sector in Poland. It grants licences and concessions, approves game rules, issues classification decisions, and authorises the technical testing of gambling machines and related devices. The Department is also responsible for matters relating to gambling tax and engages in co-operation with gambling regulators in other jurisdictions as well as international organisations active in this sector.

Enforcement and Supervision

Enforcement remains consistent and visible, with ongoing actions by the National Revenue Administration to limit the grey market and reinforce licensed operators’ positions.

Financial Crime Compliance

Gambling operators are “obliged institutions” under Poland’s AML/CFT regime and must conduct full KYC, transaction monitoring and risk assessments under the Act on Counteracting Money Laundering and the Financing of Terrorism. In parallel, phased EU MiCA implementation is shaping how operators and partners approach any crypto-linked payments or tokenised assets.

Market and Conduct Trends

There is continued pressure on unlicensed operators through domain blocking and payment interdiction measures, as well as ongoing regulatory focus on consumer protection, responsible gambling tools, and transparency of game rules in line with the existing licensing framework.

Forthcoming/Possible Legislative Changes

There has been an announced fiscal adjustment: a planned increase in the flat tax on winnings and prizes from 10% to 15% as of 2026, extending to lotteries, contests, promotional games and mutual betting.

There is policy debate on moving selected verticals from turnover-based taxation to a gross gaming revenue (GGR)-based model. These would require formal legislative amendments; until adopted, the current system applies.

Online gambling is in principle subject to a state monopoly, with two key exceptions: mutual betting and promotional lotteries, which may be lawfully offered by private operators under a licence. As a consequence, online casino games, online poker, online bingo and slot-type games fall within the scope of the monopoly and may be organised exclusively by the state-owned company Totalizator Sportowy.

Social games offered online without a monetary prize are not automatically classified as gambling. However, if their mechanics rely on elements of chance and resemble slot-type games, they may be regarded as machine games, thereby falling under the state monopoly regime.

Where uncertainty arises as to whether a given activity qualifies as a game of chance, mutual betting, card game or machine game, the minister competent for public finance has the statutory authority to issue a binding classification decision. This mechanism plays a key role in borderline cases, where elements of chance and skill overlap or where innovative game formats raise interpretative doubts under the Gambling Act.

The organisation of gambling is regulated by the Gambling Act, which distinguishes between activities that are licensed, those that fall under the state monopoly, and those that are prohibited if conducted without the required authorisation.

Land-based betting is fully open to private operators under a licence issued by the minister competent for public finance matters. In the land-based context, casino games, poker, bingo and gaming machines may be organised by private entities, subject to obtaining a concession or licence, depending on the type of game. Casinos may be operated by private companies holding a concession, whereas slot machine salons outside casinos fall within the state monopoly.

Lotteries are divided by statutory category. Number games, cash lotteries and telebingo are reserved exclusively for the state monopoly, while promotional lotteries and raffles may be organised by private entities under licence, provided that all statutory requirements are met.

The principal legislation governing gambling in Poland is the Gambling Act of 19 November 2009, which establishes the legal framework for the organisation, supervision and taxation of gambling activities. The Act defines the categories of gambling permitted in Poland, distinguishes between activities subject to the state monopoly and those available to private operators under a licence or concession, and sets out the requirements relating to licensing, player protection, responsible gambling and advertising restrictions.

The implementation of the Gambling Act is supplemented by a number of secondary regulations issued by the minister competent for public finance matters, which provide detailed rules on technical standards for gambling machines and systems, certification requirements, and the operation of monitoring and reporting mechanisms.

Procedural matters relating to administrative proceedings under the Gambling Act are governed, where applicable, by the provisions of the Tax Ordinance (Ordynacja podatkowa). As a result, proceedings concerning licensing, supervision, taxation and enforcement in the gambling sector follow the procedural framework applicable under tax law, ensuring consistency across fiscal and regulatory matters.

In addition to the Gambling Act, several other legislative instruments are relevant. The Act of 1 March 2018 on Counteracting Money Laundering and the Financing of Terrorism classifies gambling operators as “obliged institutions”, subject to KYC, reporting and internal AML procedures. Criminal fiscal liability for unauthorised gambling and related offences is regulated by the Fiscal Penal Code (Kodeks karny skarbowy). General provisions on consumer protection, personal data processing (GDPR) and electronic communications also apply, in particular to remote gambling operators.

Although the Gambling Act does not provide an explicit statutory definition of “gambling”, the scope of gambling activities is derived from Article 2 of the Act, which adopts a broad and functional approach. Gambling is understood as participation in a game organised for profit, where the outcome is wholly or partly random and participants may win a monetary or in-kind prize.

The Act distinguishes four statutory categories of gambling activities:

• games of chance (gry losowe);
• mutual betting (zakłady wzajemne);
• card games (gry w karty); and
• games on machines (gry na automatach).

This regulatory approach focuses on the substance of the activity, namely the combination of chance and the potential to obtain a prize rather than the form, mechanics or technology used. Consequently, both land-based and online activities may be classified as gambling if they meet these criteria. However, the catalogue of gambling activities is closed, meaning that only the types expressly listed in the Act are legally recognised as gambling under Polish law.

Polish law does not contain a separate statutory definition of land-based gambling, but the concept is understood through the general provisions of the Gambling Act. In practice, land-based gambling refers to all forms of gambling that are organised in physical venues such as casinos, bingo halls, betting shops and slot machine parlours rather than via telecommunications or internet systems. Land-based gambling therefore encompasses these games when offered in licensed or concession-based premises.

Under Polish law, online gambling is understood as the organisation and participation in games using the internet or other means of electronic communication, where the outcome and participation occur through remote access rather than in a physical venue.

Liability under Polish gambling law operates on two levels: administrative (under the Gambling Act) and fiscal-criminal (under the Fiscal Penal Code). On the organiser’s side, core offences include conducting or arranging gambling without the required licence, concession or notification, as well as operating games contrary to licence conditions or approved rules, using or maintaining unregistered slot machines, and advertising, promoting or sponsoring gambling in breach of statutory restrictions.

Venue owners and tenants are also liable where unregistered or illegal gambling devices are found on their premises, regardless of whether they directly operate the games. Players may incur liability for participating in unlawfully arranged gambling or for taking part in foreign gambling offered on Polish territory without authorisation.

Under the Gambling Act, an infringing organiser may face high, statutorily fixed monetary penalties that are linked to the gravity and nature of the violation. Fines are imposed for offences such as organising or conducting gambling without a required licence or concession, operating unregistered slot machines, breaching the conditions of a licence, or failing to register gambling devices. Penalties are often calculated per device or as multiples of licence fees and may reach significant amounts intended to remove the economic benefit of illegal operation. Liability also extends to venue owners or tenants who allow unregistered gambling activities on their premises, as well as to payment and telecommunications providers that fail to block transactions or access to blacklisted operators. For example, an operator offering mutual bets (sports betting) without the required licence may be fined an amount equal to five times the official licence fee.

Under the Fiscal Penal Code (Article 107), unlawful gambling constitutes a fiscal-criminal offence. Anyone who, in breach of the Act or licence conditions, organises or conducts gambling is subject to a fine of up to 720 daily rates, imprisonment of up to three years, or both (potential maximum fine amounts to PLN44,792,640 (approximately EUR9.95 million). Those who participate in a foreign gambling game or bet while on Polish territory without Polish authorisation may be fined up to 120 daily rates (maximum of PLN7,465,440 (approximately EUR1.61 million). In aggravated cases, where the offence involves organising collective participation for profit, the same maximum penalties apply cumulatively. Where the infringement is of lesser gravity, the act constitutes a fiscal misdemeanour punishable by a fine.

In parallel, administrative enforcement is supported by systemic measures such as the register of prohibited domains, blocking of payments to unlicensed sites, and the public list of authorised operators maintained by the minister competent for public finance matters.

Collectively, the minister competent for public finance matters, the National Revenue Administration and its regional authorities form a comprehensive regulatory and enforcement framework that integrates licensing, supervision, taxation and compliance oversight across both national and regional levels of the gambling market.

The minister competent for public finance matters is responsible for establishing gambling policy, granting licences and concessions for casinos and mutual betting, approving game rules and technical standards, and maintaining the official registers of authorised operators and the public blacklist of prohibited domains. The minister also issues interpretative guidance and official notices, ensuring consistent application of gambling law across all regulated activities.

For games of a limited territorial scope, including promotional lotteries specifically, the directors of revenue administration chambers (dyrektorzy izb administracji skarbowej) and heads of customs-tax offices (naczelnicy urzędów celno-skarbowych) are competent to grant licences and exercise local supervision. These bodies operate within the organisational structure of the National Revenue Administration, under the co-ordination of the minister competent for public finance matters.

Administrative enforcement is carried out through the National Revenue Administration (Krajowa Administracja Skarbowa, or KAS). Within the KAS structure, the Tax and Customs Service and the competent customs-tax and tax offices are empowered to conduct inspections, seize illegal gaming machines, enforce administrative and fiscal-criminal penalties, and collect the gambling tax.

Poland applies a predominantly prescriptive and restrictive approach to gambling regulation, supplemented by elements of risk-based supervision in specific areas such as anti-money laundering and consumer protection.

The Gambling Act sets out a highly detailed statutory framework that defines the types of gambling licensed, the entities authorised to operate them, and the licensing and technical requirements that must be met. The system is rule driven and each gambling vertical (casino, betting, lotteries, bingo, gaming machines) is governed by precise legal provisions determining the scope of permissible activities, licensing conditions, tax treatment and advertising limits.

At the same time, risk-based mechanisms apply in areas where EU law requires a more flexible approach. Under the Act on Counteracting Money Laundering and the Financing of Terrorism, gambling operators are treated as obliged institutions and must apply customer due diligence, transaction monitoring, and enhanced measures proportionate to the level of identified risk. Similarly, the minister competent for public finance matters and the National Revenue Administration conduct risk-based supervision to prioritise inspections and enforcement in higher-risk segments, such as online operations.

Under Polish law, gambling activities may be carried out only on the basis of a concession or licence, depending on the type and scope of the operation. This framework reflects the legislature’s intent to apply differentiated levels of regulatory control based on the level of risk and public interest associated with each gambling form.

A concession is required for casino-type operations, including roulette, card games, dice games and gaming machines. It represents the most stringent form of regulatory approval, issued at the ministerial level by the minister competent for public finance matters. A single concession covers all games conducted within a casino, which must operate under an approved set of internal game rules and technical standards.

A licence applies to other forms of gambling, including mutual betting. The Gambling Act differentiates between two types of betting authorisations; one for land-based betting points and another for online betting, meaning that an operator offering both formats must hold two separate licences. Licences are also required for raffles (loterie fantowe), audiotele lotteries (loterie audioteksowe), bingo games with non-cash prizes (gry bingo fantowe) and promotional lotteries (loterie promocyjne), issued by tax administration authorities.

In Poland, gambling licences and concessions are not freely or automatically available. The system is highly restrictive and prescriptive, reflecting the legislature’s intent to maintain close state control over the gambling market.

The duration of licences and concessions under Polish law depends on the type of gambling activity. A casino concession and a licence for mutual betting is granted for a period of up to six years, with the possibility of renewal upon application. Licences for other gambling activities, including cash bingo, raffles and promotional lotteries, are generally issued for a shorter period, typically up to two years. Where gambling is organised under the state monopoly, the activity continues under a statutory authorisation rather than a time-limited licence.

Licensing and Regulatory Framework

To obtain a licence or concession to operate gambling activities in Poland, an applicant must be incorporated as a limited liability company or joint-stock company with its registered seat in Poland, or operate under an equivalent corporate form within the EEA. Pursuant to Article 7a of the Gambling Act, companies established in another EU or EFTA (European Free Trade Association) member state that is a party to the EEA Agreement may conduct gambling activities in Poland on the same terms as domestic entities. However, such companies are required to establish a representative office or branch in Poland to enable effective regulatory supervision.

In each case, the registered share capital of the applicant must be not lower than PLN2 million (approximately EUR465,000) or the equivalent in another currency in the case of a foreign company. The company must also appoint a supervisory board responsible for overseeing the operations of the management board. In jurisdictions where such a body does not exist, the supervisory function may be performed by an internal committee, with its role and authority defined in the resolution on appointment.

The application process is comprehensive and document-intensive. Applicants must submit complete corporate documentation, including details of the ownership structure, share capital, and evidence confirming the lawful origin of funds used to establish or finance the business. They must further demonstrate financial stability and integrity, supported by criminal record certificates for all members of the management board, shareholders and beneficial owners, confirming the absence of convictions for fiscal, economic or corruption-related offences. In addition, each applicant is required to prepare and submit game rules and a detailed responsible gambling policy in line with statutory obligations.

Online Gambling Requirements

Operators offering gambling services online are subject to additional obligations reflecting the specific risks associated with remote gambling. Their systems must be hosted on servers located within the EEA and operate under a Polish top-level domain (.pl). They are further required to provide the competent authorities with real-time access to operational and transactional data. Online platforms must incorporate robust player identification and verification mechanisms, as well as automated tools for monitoring transactions and enforcing responsible gambling limits (including deposit and time restrictions). All payment processing must be carried out through certified financial institutions.

Technical and Supplier Obligations

Suppliers of gaming software, systems and equipment are not subject to separate licensing; however, they are required to ensure that all devices and systems used by operators are certified and registered in accordance with statutory technical and fiscal standards. Such suppliers must also maintain their data infrastructure within the EEA.

Land-Based Versus Online Operations

The principal distinction between land-based and online operators lies in the technical and localisation requirements applicable to each. Land-based operators are bound by stringent regulations regarding premises, surveillance and access control, while online operators are subject to extensive obligations concerning IT security, data localisation, remote monitoring and player verification. Despite these differences, the licensing process in both cases remains rigorous and highly formalised.

The law sets specific timeframes for the consideration of licence and concession applications. As a rule, applications for the granting of a concession or licence must be processed within six months from the date of submission. This general period applies in particular to activities such as casino operations, or mutual betting where the scope of verification and documentation is extensive. For smaller-scale gambling forms, such as promotional lotteries, audiotele lotteries and raffles, the statutory timeframe is shorter – two months from the date of application. These proceedings are typically handled by regional tax administration authorities and involve a simplified assessment procedure.

Licence Fees and Financial Security Requirements

Under the Polish Gambling Act, the fees associated with licence and concession applications are calculated as percentages of a statutory base amount (kwota bazowa), which serves as the benchmark for determining all administrative charges in the gambling sector.

The base amount for a given calendar year equals the average monthly salary in the enterprise sector (excluding profit-related bonuses) in the second quarter of the preceding year, as officially announced by the President of the Central Statistical Office (GUS) in the Official Journal of the Central Statistical Office. This mechanism ensures that the level of fees automatically adjusts to current economic conditions and inflation trends.

Licence and Concession Fees

The highest fee applies to the granting of a casino concession, set at 32,000% of the base amount, reflecting both the profitability and regulatory complexity of casino operation (PLN2,854,060.80; approximately EUR663,956). A licence to operate a cash bingo hall is charged at 5,500% of the base amount (PLN490,541.70; approximately EUR114,089), while a licence for mutual betting requires a fee of 2,000% of the base amount (PLN178,378.80; approximately EUR41,484), with additional charges depending on the form and scope of the activity. Specifically, operators must pay 50% of the base amount for each betting point (PLN4,459.47; approximately EUR1,037), 2,000% for online betting operations, and 5,000% for each website used to offer betting services (PLN445,947.00; approximately EUR103,713).

For lower-risk gambling activities, such as raffles and cash bingo, the licence fee amounts to 100% of the base amount (PLN8,918.94; approximately EUR2,075), or 50% if the activity is conducted within a single voivodeship (province) (PLN4,459.47; approximately EUR1,037). Promotional and audiotele lotteries are subject to a proportional fee equal to 10% of the total prize pool, but not less than 50% of the base amount (PLN4,459.47; approximately EUR1,037), linking the administrative cost directly to the economic scale of the game.

Amendment Fees

The Gambling Act also provides for administrative fees for modifications to existing concessions and licences. The fee for amending a casino concession is 400% of the base amount (PLN35,675.76; approximately EUR8,300), while an amendment to a standard licence costs 200% of the base amount (PLN17,837.88; approximately EUR4,148). Smaller adjustments such as changes related to a specific gaming venue or betting point, require a payment of 10% of the base amount (PLN891.89; approximately EUR207).

Financial Security Requirements

In addition to the applicable fees, gambling operators are required to provide a financial security (zabezpieczenie finansowe) to protect the financial interests of players and ensure compliance with tax obligations under the Gambling Tax Act. The amount of security depends on the type and scale of activity:

• PLN1.2 million (approximately EUR279,000) – for the operation of a casino;
• PLN600,000 (approximately EUR140,000) – for the operation of a cash bingo hall;
• PLN40,000 (approximately EUR9,300) – for each betting point; and
• PLN480,000 (approximately EUR112,000) – for online betting operations.

The number of required financial securities increases proportionally with the number of operated venues. An operator managing between one and three casinos, bingo halls or betting points must provide one financial security. This requirement rises to two securities for operators managing four to six venues, and to three securities for those with seven to nine.

Where an operator conducts activity in ten to 20 establishments, four securities are required. The obligation further increases to five securities for 21 to 30 venues, and six securities for 31 to 40 venues. For every additional ten venues above 40, the operator must provide one additional security.

Financial security may take the form of:

• bank or insurance guarantees, under which the guarantor irrevocably undertakes to pay, upon request of the licensing authority, any due gambling tax (including interest) and player claims arising from gambling participation; or
• cash deposits made to the bank account designated by the licensing authority.

Only entities authorised to issue guarantees within the EU or EFTA may act as guarantors, including banks, branches of foreign banks, and insurance undertakings operating in Poland with the right to provide guarantee instruments throughout the national territory. All deposits must be made in Polish currency (zloty).

Polish legislation does not impose annual regulatory or maintenance fees on licensed gambling operators once a licence or concession has been granted. Instead, the ongoing financial obligations arise from the gambling tax regime.

Polish gambling law does not rely on stand-alone personal licences. Instead, the Gambling Act focuses on ensuring the integrity and suitability of individuals who perform managerial or operational functions within licensed gambling companies. Personal authorisation therefore takes the form of fit-and-proper verification, rather than standalone personal licensing. Personal authorisation requirements apply to members of management boards, supervisory boards and shareholders of licensed or concession-holding entities.

Land-based gambling can only be conducted in approved and licensed venues that meet the statutory definition of gaming establishments. These include casinos, bingo halls and gaming machine salons, each of which must operate in a designated, separated area that restricts access to persons under 18 and ensures compliance with advertising and responsible-gaming rules.

A casino is defined as a dedicated venue where roulette, card, dice and machine games are conducted under an approved set of rules, with at least four live-table games and between five and 70 slot machines installed. Bingo halls are similarly defined as designated premises where cash bingo is played under a separate authorisation, and slot machine salons may host between three and 50 machines. Totalizator Sportowy is the only entity authorised to operate gaming centres in the form of slot machine gaming parlours, as it exercises the state monopoly on slot machines outside casinos.

Each venue must operate under a licence or concession granted following the submission and approval of a detailed game regulation that specifies the types of games to be offered, the technical equipment used, as well as the internal control and security measures in place. The premises must be equipped with monitoring and recording systems and must comply with all technical and operational standards established in the implementing regulations. Any modification, relocation or change in the number of games or devices requires prior approval from the competent authority.

In Poland, there is no separate or distinct B2C licence regime as known in some other EU jurisdictions. Instead, the right to offer gambling services directly to consumers is strictly regulated under the licensing system established by the Polish Gambling Act, under which the only form of B2C online gambling licence available to private operators covers mutual betting (bookmaking).

An online B2C licence for mutual betting authorises an operator to organise and offer betting services directly to consumers via the internet. Such a licence is granted by the minister competent for public finance matters and authorises the operator to organise and offer betting, provided that it complies with all statutory and technical requirements. Licensed operators must have their registered seat within the EEA, operate a “.pl” domain registered in Poland and remain accessible to the Polish supervisory authority. They are also required to implement effective age verification, anti-money laundering and responsible gambling measures.

Other forms of online gambling fall under the state monopoly exercised by Totalizator Sportowy, and cannot be offered by private entities under a B2C licence.

Polish gambling law does not provide for a separate or distinct B2B licensing regime for suppliers, software providers, etc.

Co-operation with third parties is permitted only insofar as it does not involve the direct organisation or conduct of gambling activities. Suppliers providing services or technologies to licensed operators are nevertheless subject to several regulatory and technical requirements that affect outsourcing and system integration. In particular, servers used for the operation of online gambling must be located within the EEA, and the gambling software must ensure that Polish authorities have real-time and on-demand access to all operational and transactional data, including those affecting the course of the game and financial settlements. Moreover, only certified financial intermediaries may process payments between players and operators, ensuring traceability and compliance with anti-money laundering and consumer protection rules.

Polish gambling law does not provide for a separate regulatory framework for affiliate marketing in the gambling sector. However, the use of affiliates by licensed operators is effectively regulated through the strict advertising, promotion and sponsorship restrictions set out in the Gambling Act, particularly those concerning the advertising of betting services.

Any advertising, whether direct or indirect, must comply with statutory requirements. Affiliates may only promote licensed betting operators that hold valid authorisation in Poland, while the promotion of unlicensed gambling websites is treated as illegal advertising of gambling. Websites facilitating access to unlicensed gambling are subject to blocking by internet service providers, based on entries in the official Register of Domains Used for Offering Gambling Games found promoting or supporting such websites, and may face administrative sanctions, as well as criminal fiscal liability.

There are no specific licensing or regulatory requirements governing the use of white-label providers. The Polish Gambling Act does not introduce a distinct framework for the approval or registration of white-label partners, and such arrangements are not expressly regulated or restricted. Licensed operators may co-operate with white-label providers for technical, marketing or brand-related purposes, such as platform hosting, software provision or customer interface design, as long as the licensed operator retains full legal and operational responsibility for the gambling activity itself. The licence holder must remain the entity that organises the games, accepts stakes, determines outcomes, and pays winnings, while ensuring compliance with all statutory obligations, including consumer protection, and data access requirements for supervisory authorities.

White-label co-operation is therefore permissible in Poland, but only within the limits where it serves a supporting or infrastructural role, without transferring or sharing the operator’s licensed gambling functions.

Poland has implemented technical enforcement measures to protect consumers from unlicensed gambling operators and to prevent the circumvention of national licensing rules. These measures are primarily established under the Polish Gambling Act, particularly Article 15f, which introduced a centralised system for domain and payment blocking.

Under this framework, the minister responsible for public finance maintains the register, which lists websites offering or promoting gambling services without the required Polish licence or concession. ISPs are legally obliged to block access to all domains entered in the register within 48 hours of their inclusion, effectively preventing users in Poland from accessing unlicensed gambling sites. In parallel, payment service providers (PSPs) are required to block transactions between Polish consumers and unlicensed operators whose domains appear in the register. These technical safeguards are complemented by AML/CFT and consumer protection mechanisms.

Polish gambling regulation includes responsible gambling measures designed to protect players and mitigate the social harms associated with gambling. Operators must implement a Responsible Gambling Policy that promotes safe play and ensures the protection of minors and vulnerable individuals.

This policy must include:

• visible information on the gambling operator and its contact details;
• the game rules;
• a clear statement prohibiting access for persons under 18;
• information about the risks associated with gambling; and
• details of institutions providing assistance to individuals with gambling problems.

The policy must also provide for strict age and identity verification, player registration prior to participation, and mechanisms allowing players to monitor their activity and spending. Operators are further required to implement systems that prevent play once a player’s funds are exhausted.

Online operators may initially allow participation through a Temporary Account prior to full verification; however, such an account must be suspended after 30 days if the player’s identity has not been confirmed. Once suspended, no further gambling activity or marketing communication directed at the holder of the temporary account is permitted.

The Responsible Gambling Policy must be approved by the minister competent for public finance before gambling operations commence, and operators are required to ensure ongoing compliance with its provisions throughout their activity.

Operators are required to implement technical and organisational measures that enable effective control over player participation and spending, ensuring that gambling activities are conducted responsibly and transparently. All players must be registered and verified before taking part in any legal gambling activity, whether land-based or online. This system serves to prevent underage participation and ensure compliance with anti-money laundering obligations.

Online operators must also provide players with tools to set deposit, time and spending limits, allowing them to determine maximum deposit amounts, stake limits or session durations. These mechanisms promote self-control and help prevent excessive or impulsive gambling behaviour. Additionally, gambling systems are required to offer self-exclusion options, enabling players to voluntarily block access to gambling for a specified period or permanently. Operators must ensure that minors and self-excluded individuals cannot access the system under any circumstances.

Licensed operators must maintain detailed records of all gambling transactions and player activity, ensuring that each player has access to a transparent account history, including deposits, wagers, winnings and losses. Both physical venues and online platforms must clearly display responsible gambling information, warnings about the risks of gambling, age restrictions and contact details for organisations providing professional assistance with gambling-related problems.

Unlike in many other European jurisdictions, Polish gambling law does not impose statutory limits on stake or deposit amounts, nor does it restrict in-play (live) betting, apart from the temporary limitations applicable to unverified Temporary Accounts. The regulatory approach thus focuses on operator-driven responsibility and player self-regulation, rather than fixed statutory constraints.

The primary legal instrument governing AML/CFT obligations in Poland is the Act of 1 March 2018 on Counteracting Money Laundering and the Financing of Terrorism (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu). This Act implements EU directives and establishes national mechanisms for AML/CFT supervision.

Under Article 2(1)(20), entities conducting activities in the field of games of chance, mutual betting, card games and machine games are expressly classified as obliged institutions. The General Inspector of Financial Information (Generalny Inspektor Informacji Finansowej) is designated as the central authority responsible for counteracting money laundering and terrorist financing (Articles 10–12), while overall AML policy co-ordination rests with the minister competent for public finance matters (minister właściwy do spraw finansów publicznych).

The Act also provides for a dual-level risk assessment system: the National Risk Assessment, prepared by the General Inspector in co-operation with competent authorities and obliged entities, taking into account EU-level analyses (Article 25), and the Institutional Risk Assessment, conducted by each obliged entity, including gambling operators, covering factors such as customer profiles, geography, products, services and transaction channels (Article 27).

Under the Polish AML framework, obliged institutions, including gambling operators, are required to implement a comprehensive set of measures designed to prevent money laundering and terrorist financing. They must conduct both institutional risk assessments and ongoing reviews of their exposure to AML/CFT risks.

Operators are obliged to apply financial security measures, which include the identification and verification of customers and beneficial owners, the assessment of business relationships and the continuous monitoring of transactions. These measures must in particular be applied when accepting stakes or paying out winnings of EUR2,000 or more, whether as a single or related transaction. Each obliged institution is required to establish and maintain internal AML policies and procedures proportionate to the nature and scale of its business, appoint a person responsible for AML compliance, and ensure regular staff training. Institutions must also keep records of customer due diligence and transactions for at least five years following the end of the business relationship or the execution of a transaction, and co-operate with competent authorities when requested. Breaches of AML duties may result in administrative fines, other corrective measures or criminal liability of management.

In practice, this system obliges gambling operators to adopt a risk-based approach that integrates due diligence, transaction monitoring, internal controls and reporting procedures into their daily operations to ensure the effective prevention of money laundering and terrorist financing.

Under the Polish Gambling Act, the minister competent for public finance matters serves as the primary regulatory and supervisory authority responsible for overseeing compliance with gambling legislation, including advertising restrictions. The Minister exercises these powers through the KAS – in particular, the Head of the National Revenue Administration, directors of revenue administration chambers, and heads of customs and tax offices.

Under the Polish Gambling Act, advertising of gambling games is understood as any public communication involving the dissemination of trade marks, symbols, names or other identifiers associated with entities operating in the field of gambling. It also includes the sharing of information about where such games are organised and how participation is possible.

The definition adopted by the Polish legislature is broad and objective, focusing on the act of public dissemination rather than the intent behind it. It encompasses any activity that publicly exposes or associates a name, logo, or symbol with gambling operations, even where the communication does not explicitly encourage participation. This formulation deliberately extends beyond the traditional understanding of advertising known from consumer law, removing the subjective element of intent to promote or influence consumer behaviour. As a result, even indirect or incidental use of gambling-related names or symbols in public spaces may fall within the scope of the advertising prohibition.

In practice, however, the interpretation of advertising rules has been clarified by the minister competent for public finance. According to official explanations, online advertising of gambling services is not subject to temporal restrictions, meaning that licensed operators may lawfully conduct marketing activities on the internet at any time of day.

Unlike in many other European jurisdictions, Polish law does not impose broader marketing restrictions, such as a general ban on online advertising, prohibitions on offering bonuses or promotional incentives, or time-of-day limitations. Instead, the regulatory framework focuses on ensuring that only licensed operators may advertise their services and that marketing content remains compliant with responsible gambling principles and does not target minors or vulnerable individuals.

The regulation of gambling advertising in Poland is primarily governed by the Gambling Act, which sets out the legal framework for the organisation, supervision and control of gambling activities, including rules on advertising, promotion and sponsorship. Under Articles 29–29b, the Act introduces the general statutory framework for gambling advertising and promotion, defining the scope of what constitutes advertising and identifying the limited circumstances in which it may be lawfully conducted.

The provisions on advertising are designed to ensure that gambling remains a strictly regulated activity and is not promoted as a form of entertainment or investment. The legislature adopted an intentionally restrictive and preventive approach, aimed at limiting the social and psychological risks associated with gambling and protecting vulnerable individuals. All licensed and authorised entities are required to comply strictly with these provisions.

Advertising in the gambling sector in Poland is subject to strict statutory restrictions set out in the Gambling Act, which establishes a general prohibition on the advertising and promotion of gambling activities, as well as on the dissemination of information regarding sponsorship by gambling operators.

Exceptions to this rule apply exclusively to licensed betting activities, and even then, advertising is permitted only under narrowly defined statutory conditions. Such advertising may solely concern operators holding valid licences in Poland and must relate directly to their authorised offer.

Advertising must not present gambling in a positive light or as a means of achieving financial success, social prestige or personal fulfilment. It may not suggest that gambling can resolve financial difficulties, improve wellbeing, or be regarded as a display of skill or success. Furthermore, advertising must not target minors, depict minors or use their image in any context.

Broadcast advertising is prohibited on radio and television between 6am and 10pm, and gambling-related advertisements are not permitted in schools, educational institutions, public facilities or any other places where minors may be present.

Advertising of licensed betting activities must remain factual and strictly informational, limited to identifying the operator and its licensed offer. Each advertisement must also include a mandatory warning concerning the risks of gambling addiction and the prohibition of participation by minors.

The Polish legal framework imposes a comprehensive and preventive advertising regime, combining strict statutory prohibitions with administrative and criminal enforcement mechanisms to ensure that gambling remains a highly regulated and socially contained activity.

Under Article 59 of the Gambling Act, licensed entities that breach advertising prohibitions or conditions may face administrative sanctions, including the revocation or suspension of a licence or concession. In addition, criminal fiscal liability arises under the Fiscal Penal Code (Kodeks Karny Skarbowy), which provides that any person who, in breach of the Gambling Act, commissions, conducts or benefits from gambling advertising or promotion, or disseminates information about sponsorship by gambling entities, may be held criminally liable.

Any change in the ownership structure of a licensed gambling company such as the acquisition of shares, alteration of the shareholding composition, or a transaction resulting in a change of control must be reported to the competent licensing authority. This obligation ensures that the authority can verify whether the new shareholders or controlling entities continue to meet all statutory conditions required for holding a concession or licence, including those relating to the legality of capital origin and tax compliance. Failure to disclose such changes may result in administrative sanctions, including the revocation of the licence or concession, under the general enforcement provisions of the Gambling Act.

Any change in a company’s share capital structure that causes a shareholder’s votes or equity to cross specified thresholds (10%, 20%, 30%, 40%, 50%, 75%, 90%) is a trigger. The company must notify the competent authority within seven days of the change’s registration in the National Court Register; the notice must identify the acquirer (company or individual) and be supported by specified documents (eg, corporate documents/clean-record confirmations and proof of lawful funds). If, as a result of such ownership changes, the beneficial owner (beneficjent rzeczywisty) of the licensed entity is altered, this information must also be disclosed and updated in accordance with the applicable registration and notification obligations.

Under the Polish Gambling Act, even passive investors, those acquiring or holding shares in a licenced gambling company without exercising management or operational control, are subject to regulatory scrutiny. All investors are assessed before a licence or concession is granted, to ensure that the ownership structure, the integrity of shareholders, and the source of investment funds meet statutory requirements.

Subsequently, any acquisition or transfer of shares that results in a shareholder’s votes or equity crossing specified thresholds must be reported to the competent authority. This obligation applies equally to passive investors and active controlling shareholders. The purpose of the notification is to enable the authority to verify whether the new investor continues to satisfy all statutory requirements, including integrity, financial reliability and transparency of ownership.

Enforcement powers in the gambling sector are primarily exercised by the minister competent for public finance matters, acting through the National Revenue Administration. These authorities are responsible for supervising compliance with the Act, including licensing conditions, advertising restrictions, reporting duties and technical requirements for gambling operations.

Regulatory and enforcement powers include the right to conduct inspections, request information and documentation, and access business premises and gambling equipment. Authorised officers of the customs and tax administration may carry out inspections to verify compliance with the provisions of the Gambling Act, its implementing regulations and the tax legislation applicable to gambling activities. These inspections cover, in particular, the legality of gambling operations, adherence to licence or concession conditions, compliance with advertising and technical standards, and the correct calculation and payment of gambling-related taxes and fees.

Administrative sanctions are imposed in cases of non-compliance with licensing conditions or breaches of statutory prohibitions, such as the unlawful organisation of gambling or violation of advertising restrictions. Under the Gambling Act, the competent authority may issue a decision ordering the removal of identified infringements, revoke a licence or concession, or refuse to renew authorisation. Financial penalties may also be applied under the Gambling Act and relevant tax legislation, for failure to meet reporting or payment obligations.

Criminal fiscal sanctions are enforced under the Fiscal Penal Code which provides for fines and other penalties for serious offences, including the illegal organisation of gambling, the use of unapproved gambling machines, or unlawful advertising and promotion of gambling. In such cases, proceedings are initiated by the customs and tax control authorities and adjudicated by the competent courts. In addition, enforcement authorities have powers to secure evidence, seize gambling equipment, and block illegal online gambling websites. These measures are used to prevent access to unlicensed operators and to protect the regulated market.

As for enforcement history, Poland has maintained an active and consistent enforcement policy since the 2017 amendments to the Gambling Act, which significantly expanded the powers of the National Revenue Administration. Numerous administrative and fiscal proceedings have been initiated against entities operating without authorisation or breaching advertising restrictions, and illegal online gambling sites are regularly included in the official register of blocked domains maintained by the minister competent for public finance matters. This consistent record of enforcement demonstrates a strong regulatory stance aimed at maintaining market integrity and compliance with statutory obligations.

Enforcement and Financial Penalties

The Polish Gambling Act provides for a comprehensive system of financial and administrative penalties applicable to breaches of licensing, operational and compliance obligations. Financial penalties may be imposed for, among others, the organisation of gambling without the required licence, concession or notification; failure to comply with the terms and conditions of an authorisation; conducting gambling activities outside the authorised scope or location; use of unregistered or non-compliant gaming equipment; obstruction of inspections or failure to provide required information; as well as violations of advertising, promotion and sponsorship restrictions.

In some cases, the Act stipulates fixed or predetermined penalty amounts, while in others, the competent authority may impose a fine up to the statutory maximum provided for the specific infringement. Each case is assessed individually, taking into account the nature, scale and circumstances of the violation.

Examples of Financial Penalties

The following penalties may apply.

• Operating gambling facility without a licence, concession or notification:
1. for gaming machines – PLN100,000 (approximately EUR23,000) per machine;
2. for other types of gambling – five times the licence or concession fee; and
3. for gambling organised without mandatory notification – up to PLN10,000 (approximately EUR2,300).
• Operating contrary to the terms of authorisation:
1. up to PLN200,000 (approximately EUR46,500) for activities under a licence or concession; and
2. up to PLN10,000 (approximately EUR2,300) for activities conducted under a notification.
• Possession of premises with unregistered gaming machines – PLN100,000 (approximately EUR23,000) per machine (applicable to both dependent and independent possessors).
• Payment service providers violating statutory restrictions – up to PLN250,000 (approximately EUR58,000).
• Telecommunications operators failing to comply with domain-blocking obligations – up to PLN250,000 (approximately EUR58,000).
• Unlicensed organisation of games within the state monopoly – up to PLN500,000 (approximately EUR116,000).
• Participants in illegal gambling – a fine equal to 100% of the winnings obtained, without deduction of stakes.
• Management or board members of entities operating without authorisation may also face personal financial penalties up to PLN100,000 (approximately EUR23,000).

Enforcement Procedure

Pursuant to the enforcement provisions of the Gambling Act, financial penalties constitute public-law liabilities and are collected in accordance with tax enforcement procedures. Once a penalty decision becomes final, it is immediately enforceable as an administrative act, and the amount due may be recovered through compulsory measures, including the seizure of bank accounts, funds or property.

The enforcement process follows the same procedural framework as the recovery of tax arrears, ensuring that penalties are executed effectively and that operators remain compliant with regulatory decisions.

The applicable tax rates vary depending on the type of gambling activity, and the tax base is determined specifically for each category of game. Lotteries are taxed at a rate of 15% of the total value of ticket sales or other evidence of participation in the game, while raffles and non-cash bingo are taxed at 10%. Number games, such as Lotto, are subject to a 20% tax on the total amount of stakes paid. Cash bingo, telebingo, poker tournaments, and audiotele lotteries are taxed at 25% of the total value of stakes or equivalent amounts. Casino games, including roulette, card games, dice games, and gaming machines, are taxed at 50% of gross gaming revenue, calculated as the difference between the amounts staked and the winnings paid out. For sports betting, two rates apply: 2.5% of stakes for betting on animal sports, and 12% of stakes for all other forms of betting.

Taxpayers are licensed or authorised gambling operators, who must calculate and remit the gambling tax. As a rule, tax is declared monthly and paid by the tenth day of the following month, while for number games it is assessed daily, no later than the tenth day after the draw.