Inside Poland’s Competition Enforcement Surge & the Growing Risk Facing Executives

Key Takeaways

• Personal Liability Became Real in 2025: UOKiK imposed direct fines on individual managers, while Polish courts reinforced the idea that executives can be held responsible for failing to oversee anti-competitive conduct properly.
• Labour Market Practices Are Now an Antitrust Target: Investigations involving Biedronka and transport contractors signaled a growing focus on alleged no-poach agreements and labour market coordination.
• Greenwashing Enforcement Is Expanding: Cases against Allegro, DHL, DPD, and InPost showed regulators increasingly targeting environmental claims that may be technically accurate but misleading in context.
• Digital Commerce Scrutiny Intensified: Zalando and Temu faced fines tied to pricing transparency rules, while Apple encountered abuse-of-dominance allegations connected to App Tracking Transparency.
• Early Engagement With Regulators May Reduce Risk: More than half of companies receiving informal warnings over payment practices changed their behavior without triggering formal proceedings, suggesting regulators are prioritizing corrective action alongside penalties.

Deep Dive

The fine that caught people's attention $78 million (PLN 339 million), split between an agricultural machinery company and the executives who ran it) wasn't the largest UOKiK imposed last year. It wasn't even close. But it was, in its way, the most instructive. Because the executives didn't argue they'd ordered the conduct. They argued they hadn't known about it. The court wasn't moved.

The UOKiK's 2025 annual report documents not just a record year of enforcement, but a structural shift in who is being held responsible. The office issued 900 decisions and collected $267M (PLN 1.15 billion) in fines. Consumers received at least $37M (PLN 160 million) in direct benefits. The numbers are striking. The more important development is quieter and it concerns the people in the room when compliance decisions get made or, more often, don't.

UOKiK imposed $325,000 (PLN 1.4 million) in fines directly on individual managers in 2025. In isolation, that figure is modest. As a signal, it is not. The Court of Appeal reinforced the point when it upheld a cartel ruling in the fitness sector that named both companies and the managers who ran them. Polish courts, it now appears, are comfortable with the argument that oversight is a duty, not a courtesy.

For GRC professionals, this is the part of the report worth sitting with. Personal liability has appeared in Polish enforcement frameworks before, mostly as theoretical exposure. 2025 was the year it became operational. The question for management boards is no longer whether this applies to them but what, concretely, they have on paper to show that they took their obligations seriously. A compliance programme that exists primarily to signal intention will not hold up to that scrutiny.

The labour market cases are a different kind of development, which is new territory rather than accelerating enforcement in a familiar area. The most prominent involved Biedronka, Poland's dominant discount grocery chain, its network of 32 transport contractors, and eight named managers. The allegation is that a no-poach arrangement prevented drivers from moving between companies serving the retailer's distribution centers.

This is antitrust enforcement reaching into HR policy, and it followed a European Competition Day that UOKiK hosted in 2025, as part of Poland's Council of the EU presidency, where labour market coordination was a central theme. Informal recruitment understandings, non-solicitation clauses buried in service agreements, and nods across a table at an industry dinner are now within scope.

The greenwashing cases are worth reading carefully, because the mechanism UOKiK used is replicable almost anywhere. The authority brought charges against Allegro, DHL, DPD and InPost not for making things up, exactly, but for making claims that were technically accurate in a narrow sense and misleading in a practical one. "Climate neutral." "Zero-emission."

The problem, in each case, was that the claim applied to one slice of the business while implying something about the whole. UOKiK decided that the implication was the communication. The EU's Empowering Consumers Directive, which takes effect in September 2026, will make this harder to contest. Marketing and legal teams reviewing environmental claims now, before the directive applies, have a narrowing window.

The digital enforcement actions are familiar in type if not in scale. Zalando was fined nearly $7.2 million (PLN 31 million) for failing to display the lowest price from the preceding 30 days before applying a promotional discount, as required under the Omnibus Directive. Temu received a fine of approximately $1.4 million (PLN 6 million) for equivalent conduct. Apple faces abuse-of-dominance charges over its App Tracking Transparency framework.

These are not novel legal theories, and the UOKiK has been building digital enforcement capability for several years. The fines are larger now, and the office has signaled that pricing algorithms and interface design are being reviewed for so-called dark patterns as a matter of course.

The payment-practices enforcement is less glamorous but affects a wider range of businesses. UOKiK reviewed nearly four million invoices last year and identified late-payment backlogs exceeding $204 million (PLN 881 million). Twenty-nine formal decisions followed, yielding fines of more than $2.3 million (PLN 10 million), concentrated in automotive, machinery and food supply chains.

One detail is worth noting is that the office also issued 177 informal warnings, and more than half of the companies that received them permanently changed their payment practices without triggering a formal proceeding. That ratio is not nothing. It suggests that UOKiK is, in this area at least, as interested in changing behavior as in collecting fines, and that companies willing to engage early are being given the opportunity to do so.

The headline number is $267 million (PLN 1.15 billion) in fines, but the more useful number is the proportion of warned companies that fixed their practices and walked away. For businesses currently outside formal proceedings, 2025 is not just a cautionary tale. It is a description of what is now being measured, by whom, and with what consequences, which is, in the end, exactly the information you need to decide where to act first.

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