POLAND Law and Practice Contributed by: Marek Plota and Anna Klaja-Gogolewska, RM Legal
1. Introduction 1.1 Current Outlook and Recent Changes 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 cor- responding 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 compe- tent for public finance, is the central regulatory author- ity for the gambling sector in Poland. It grants licences and concessions, approves game rules, issues clas- sification decisions, and authorises the technical test- ing of gambling machines and related devices. The Department is also responsible for matters relating to gambling tax and engages in co-operation with gam- bling regulators in other jurisdictions as well as inter- national organisations active in this sector. Enforcement and Supervision Enforcement remains consistent and visible, with ongoing actions by the National Revenue Adminis- tration 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 opera- tors through domain blocking and payment interdic- tion measures, as well as ongoing regulatory focus on consumer protection, responsible gambling tools, and transparency of game rules in line with the exist- ing 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 rev- enue (GGR)-based model. These would require for- mal 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 con- sequence, 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. How- ever, 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. 2. Jurisdictional Overview 2.1 Online Gambling 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
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