Poland’s consumer protection authority has intensified scrutiny of the country’s regulated betting market, launching investigations into whether major bookmakers use manipulative interface designs or unfair contractual terms when dealing with customers.
The Office of Competition and Consumer Protection (UOKiK), led by President Tomasz Chróstny, is examining both the digital design of betting services and the conditions governing customer accounts, wagers and payouts. The regulator confirmed that its review covers some of Poland’s largest licensed operators, including STS, Fortuna, Superbet, Fuksiarz, E-toto, LV Bet and Totalbet.
The intervention adds a stronger consumer-rights dimension to oversight of Poland’s gambling sector, which has traditionally centred on compliance with the Gambling Act and supervision by the Ministry of Finance and the National Revenue Administration.
UOKiK targets potentially manipulative betting features
A major part of the investigation concerns so-called dark patterns — design techniques capable of influencing customer decisions through the layout of websites, mobile apps, notifications or other parts of the betting process.
UOKiK is assessing whether operators use features that could encourage players to gamble more frequently or make it unnecessarily difficult for them to stop betting. The regulator is also looking at how bookmakers communicate with customers and whether the overall structure of their platforms creates additional risks for people vulnerable to problematic gambling behaviour.
The investigation is broader than advertising alone. It covers the full customer journey, potentially including how markets, odds, promotions, account controls and player communications are presented.
Polish gambling-law specialist Dr Justyna Grusza-Głębicka, representing the Institute for Gambling Regulation, said the action represents an important development because detailed standards governing the design of online gambling products remain limited.
Licensed bookmakers already operate under gambling legislation, responsible gambling obligations and general consumer-protection rules. However, according to Grusza-Głębicka, Poland has not established sufficiently detailed sector-specific guidance covering areas such as interface architecture, notifications, player journeys and engagement mechanisms.
Betting terms and account restrictions under review
UOKiK is separately investigating whether bookmaker terms and conditions contain provisions that unfairly disadvantage customers.
Particular attention is being paid to clauses allowing operators to cancel bets, suspend or block accounts and determine whether or when winnings will be paid.
The authority argues that customers should be able to understand in advance when such measures can be taken and what consequences they may face.
Formal proceedings concerning potentially unfair contract terms involve STS, Fortuna, Superbet, Fuksiarz and E-toto. Operators found to have breached Polish consumer law could face penalties of up to 10% of annual turnover.
The regulator’s intervention therefore extends beyond whether individual contractual provisions are legally valid. It also raises questions about how those rules are displayed to customers and applied in practice.
Industry calls for clearer standards
The Institute for Gambling Regulation has argued that stronger consumer protection should be accompanied by clearer regulatory guidance for licensed operators.
Grusza-Głębicka said regulators need to establish predictable boundaries between ordinary customer-engagement tools and product features that could be considered manipulative or harmful.
Without more precise standards, operators may have difficulty determining how broad consumer-protection requirements should apply to specific digital features, particularly as online betting products become increasingly sophisticated.
The institute has also warned that enforcement against licensed companies should be considered alongside Poland’s continuing challenge from illegal gambling platforms.
Unlicensed operators are not subject to the consumer-protection, responsible gambling and advertising requirements imposed on regulated bookmakers. FIRH therefore argues that consumer policy should also ensure players are effectively directed toward licensed platforms where regulatory protections can be enforced.
UOKiK’s investigations could consequently become an important test for Poland’s betting regulatory framework, potentially influencing future standards for sportsbook interfaces, customer contracts and responsible gambling mechanisms across the licensed market.