Poland Online Gambling Regulation, Licensing & Tax Regime

Poland's gambling enforcement architecture tightened with the launch of BLIK payment-rail blocking of illegal-gambling domains, layered on top of the existing ISP-level DNS blocking regime. The payment-processor mechanism, approved by the President of Narodowy Bank Polski and operative from 1 September 2026, checks the destination domain of each transaction against the Ministry of Finance's illegal-gambling register, which holds over 55,000 domains. Multiple legislative proposals — a loot-box gambling classification bill, an influencer-promotion criminalisation bill, and an amendment to the Gambling Act's domain-register and fine-authority provisions — remain pending before the Sejm and Senate respectively, none yet enacted. The state monopoly operator, Totalizator Sportowy, continued commercial expansion through a new online-casino brand and a new lottery supply contract.

## Licence Triggers The conditions for obtaining a licence derive from the Gambling Act. General rules: a licence or a permit may be applied for by entities, which are able to demonstrate: 1) lawfulness of sources of funds; 2) due payment of taxes constituting the income of the state budget and other customs duties; 3) due payment of contributions to social and health insurance system; 4) the compliance of their activities with the following applicable provisions: (i) provisions on counteracting money laundering practices and financing of terrorism (ii) provisions on accountancy. The above provisions shall be applied accordingly to the entities which do not have the registered office or place of residence in the Republic of Poland. ## Type of licenses needed There are three types of licences required for offering gambling games to Polish residents, i.e.: (i) a licence to run a land-based casino; (ii) a permit to offer online gambling games; and (iii) a notification on commencement of a licensable activity. As this publication focuses on the activities of operators which offer gambling that can be carried out via the Internet, we will continue to focus on the point (ii). The Minister of Finance issues permits for online betting. The Director of the competent Revenue Administration Regional Office issues permits for organising online promotion lotteries. ## Period of licence & renewal process As a general rule, a permit is issued for a period of six years and can be extended for an additional term of six years. ## Application timeframe and phrases The licensing procedure should be completed within six months from the date of filing an application, though it is legally allowed for the regulator to extend the deadline. In practice, the licence proceedings usually last longer, which should be taken into account by each applicant. List of documents & type of information needed to support application The Gambling Act requires a number of documents to be provided together with the application form, although those provisions are considered as not offering much guidance as to the content of the documents required. Each operator must provide AML documentation confirming the legality of funds used to organise gambling under a licence. Furthermore, the Gambling Act requires that online betting operators use only payment methods (bank transfers, credit cards, payment institution services, etc.) which ensure that money used for betting originates from a verified source. Foreign operators submitting documents with the application must ensure that documents are translated into Polish by a certified (court) translator. Moreover, if the regulator determines that a given document does not comply with the requirements, the applicant will be requested to provide additional documentation or supplement the document. Clarifications or additional explanations might be expected in the process, particularly in relation to the terms and conditions of the game. The terms and conditions of the game is an obligatory document to be submitted with an application, which is subject to the Minister’s approval. ## Geographical cover Poland only ## Mechanics of the licence process Can apply at any time ## Bad Actor / Cooling off periods The betting activity may be conducted on condition that: There are no justified reservations about the given company or its shareholders holding shares whose value exceeds 10% of the share capital of the company, or members of the company’s management board, supervisory board or audit committee, or the company’s proxies, being natural persons, legal persons or companies without legal personality, concerning State security, public order, the security of economic interests of the State, and compliance with provisions on counteracting money laundering and terrorism financing; No proceedings concerning criminal offences related to money laundering and terrorism financing are pending against the persons listed above (point ‘a’) before the judicial authorities of a Member State of the European Union or a member state of the European Free Trade Association (EFTA) - a party to the Agreement on the European Economic Area; The company has not had a licence or permit revoked for the reason that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the six years preceding the date of submission of the application for a licence or a permit; The shareholders (partners) of the Company, have not been shareholders (partners) holding shares whose value exceeded 10% of the company’s share capital in a company that has had a licence or permit revoked for the reason that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the 6 years preceding the date of submission of the application for a licence or a permit; The members of the management board, supervisory board or audit committee or the proxies referred to point ‘a’ above, have not been members of the management board, supervisory board or audit committee or proxies in a company that has had a licence or permit revoked for the reasons that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the 6 years preceding the date of submission of the application for a licence or a permit; and Good repute requirement: Natural persons being shareholders of a company conducting activities, representing at least 10% of the share capital, and members of the management board, supervisory board, or audit committee or proxies of such a company shall have a good reputation; in particular, they may not have a criminal record for intentional criminal offences or intentional fiscal offences in a Member State of the European Union. ## Applicant considerations Conducting an activity within the scope specified in the Gambling Act is possible only in the form of: A joint-stock company or a limited liability company having the registered office within the territory of the Republic of Poland; or Joint-stock companies or limited liability companies, or companies whose activity is based on the principles of operation of a joint-stock company or a limited liability company, having their registered office in another Member State of the European Union may pursue activities in the Republic of Poland in line with the principles and conditions defined in the approved rules of operation (T&Cs), permit granted, as well as resulting from the provisions of the Act, provided that a representative is appointed, or in the form of a branch, i.e. a separate and organisationally independent part of business activity. The following persons pursuing business activity in the Republic of Poland may act as representatives: A natural person having their place of residence within the territory of the Republic of Poland and being able to communicate in the Polish language insofar as is necessary to perform the duties of a representative; or A legal person or an organisational unit without legal personality having their registered office within the territory of the Republic of Poland, whose management board has at least one member being able to communicate in the Polish language insofar as is necessary to perform the duties of a representative. The officers of such companies, i.e. members of the company’s management board, supervisory board or audit committee, must hold Polish citizenship or that of another EU/EEA member state. Activity may be conducted on the condition that: There are no justified reservations about the given company or its shareholders holding shares whose value exceeds 10% of the share capital of the company, or members of the company’s management board, supervisory board or audit committee, or the company’s proxies, being natural persons, legal persons or companies without legal personality, concerning State security, public order, the security of economic interests of the State, and compliance with provisions on counteracting money laundering and terrorism financing; No proceedings concerning criminal offences related to money laundering and terrorism financing are pending against the persons listed above (point ‘a’) before the judicial authorities of a Member State of the European Union or a member state of the European Free Trade Association (EFTA) - a party to the Agreement on the European Economic Area; The company has not had a licence or permit revoked for the reason that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the six years preceding the date of submission of the application for a licence or a permit; The shareholders (partners) of the Company, have not been shareholders (partners) holding shares whose value exceeded 10% of the company’s share capital in a company that has had a licence or permit revoked for the reason that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the 6 years preceding the date of submission of the application for a licence or a permit; The members of the management board, supervisory board or audit committee or the proxies referred to point ‘a’ above, have not been members of the management board, supervisory board or audit committee or proxies in a company that has had a licence or permit revoked for the reasons that the conditions provided for in the licence, permit, or the rules, or other legal conditions for pursuing the activities for which the licence or permit has been granted have been grossly breached within the 6 years preceding the date of submission of the application for a licence or a permit; and Good repute requirement: Natural persons being shareholders of a company conducting activities, representing at least 10% of the share capital, and members of the management board, supervisory board, or audit committee or proxies of such a company shall have a good reputation; in particular, they may not have a criminal record for intentional criminal offences or intentional fiscal offences in a Member State of the European Union. The persons referred to above shall, upon request of the licence- or permit- granting authority, provide a valid certificate of no criminal record for intentional criminal offences or intentional fiscal offences in a Member State of the European Union. Those provisions apply accordingly to natural persons who are not-nationals of a Member State of the European Union. There are some additional requirements concerning share capital, financial securities and fees. A licensee pays a one-off licence fee for the grant of a licence or a permit, for a licence or permit renewal and/or for an amendment to a licence or permit. ## Localisation An entity organising gambling games over the Internet may use only a website whose national top-level domain is assigned to Polish websites for the purpose of their organisation.

Entry costs are significant: minimum PLN 2,000,000 share capital for a betting operator (PLN 4,000,000 for casinos), plus PLN 480,000 financial security for an online betting operator (bank/insurance guarantee or deposit) to secure tax and player claims. Application fees are linked to the statutory base amount and number of websites. The capital and guarantee thresholds are a meaningful barrier to entry.

## Regulating bodies General supervisory authority for gambling rests with the minister competent for public finance i.e. Ministry of Finance. The ongoing supervision of gambling in Poland, as well as enforcement, is carried out by the National Revenue Administration. The Opole Customs and Fiscal Office (Opolski Urząd Celno-Skarbowy) has been appointed to deal with matters relating to the Register of domains used to offer gambling in contravention of the Act. ## Supervision by Regulator Entities organising gambling games and conducting activity in this area shall be obliged to provide, at the request of the minister in charge of public finance, information concerning their functioning. Entities organising and conducting activity in the area of gambling games shall be obliged to submit to the minister in charge of public finance or the director of a tax administration chamber competent to grant a given licence, as appropriate, by 21st day of the month following every calendar quarter, economic and financial data related to their activity, with a special emphasis on the turnover, the financial result, economic indicators, in particular the employment rate, and statistical indicators used by those entities. The procedure of transmission and the detailed scope of the data are defined by a new regulation of the Minister responsible for public finance of 29 March 2022 Pursuant to the applicable regulation, the entity organising and conducting gambling activities shall transmit, among others, the following data: data confirming the fulfilment of the condition - in the case of betting on guessing virtual events; number of players and other player statistics - in the case of online gambling, i.e. data on the number of players by age bracket on the last day of the reporting period; data on player activity in the reporting period; data on gaming activity in the reporting period data to verify the compliance of the activity with the licence or permit granted and with the approved gambling regulations, and to shape gambling policy. ## Enforcement against licensed operators If a licensed operator breaches the law, the licence or the provisions of its T&Cs, the Minister of Finance may issue a decision requiring the company to cure deficiencies within a determined period. Furthermore, the regulator may revoke the licence in the following cases: (i) the operator fails to cure deficiencies in a timely manner; (ii) the operator materially breaches any provisions of law which apply to the gambling operations; (iii) the share capital of the operator is reduced below the statutory minimum; (iv) the company decides to resign from operating games or does not offer them for a period of six months (the latter applies only to casinos and bingo game arcades); (v) a board member or a shareholder is convicted for a money-laundering crime; (vi) a minor participates in games twice in the same betting arcade (does not apply to online betting); (vii) the company fails to provide AML documentation as requested by the regulator; (viii) the company fails to provide an audited financial statement (or when the auditor’s opinion indicates material breach of accounting laws); or (ix) the company has been conducting gaming activity through a foreign EU/EFTA operator without having appointed a representative for a period of at least two months. The decision on licence revocation is effective at the moment of its receipt; therefore, the operator whose licence has been revoked must refrain from operating, even if it decides to challenge the decision (the obligation to refrain lasts for the period of an appeal procedure). ## Typical triggers for enforcement against unlicensed operators Sanctions can be initiated particularly against payment service providers providing payment services on a website using an Internet domain name entered in the Register of Domains Used for Offering Gambling Games Contrary to the Act, kept by the Minister of Finance. Sanctions can also be initiated against telecommunications undertakings that have not fulfilled the obligations to prevent access to internet websites which have been blacklisted and fail to redirect attempted connections to a website run by the Ministry of Finance. ## Enforcement action taken against unlicensed operators Criminal and administrative sanctions are the enforcement method in Poland. Sanctions can be initiated against illegal gambling operators as well as players using these illegal websites. Sanctions can be initiated particularly against: illegal gambling operators; users playing on illegal websites; participant in the process of production or dissemination of gaming advertisements in breach of the law; payment service providers providing payment services on a website using an Internet domain name entered in the Register of Domains Used for Offering Gambling Games Contrary to the Act, kept by the Minister of Finance; telecommunications undertakings that have not fulfilled the obligations to prevent access to Internet websites using the names of blacklisted domains and to redirect connections referring to blacklisted domains to a website run by the Ministry of Finance. Criminal sanctions: formal investigation against persons involved in organising gambling games without a licence, persons who advertise them contrary to the law, or gamblers playing unlicensed games may be commenced upon the provisions of law, as all of the above mentioned constitute criminal fiscal offences. Administrative sanctions: financial penalties, a right to blacklist a domain which is used to organise and offer unlicensed gambling to Polish individuals and a website blocking procedure – once the domain is blacklisted, the internet service provider is obliged to block the website to unable its further use by individuals. Betting An amendment to the Gambling Act introduced 1 June 2021 provides significant change in the field of blacklisting of domains. According to the Act, foreign and domestic operators offering online betting without a licence shall expect entering the domain used for organising betting to be entered in the Register of Domains Used for Offering Gambling Games Contract to the Act (the Registry). According to the new sound of Article 15f, paragraph 4, domains available to Internet users located in the territory of the Republic of Poland shall be entered in the Register. According to the previous regulation, in order to register a domain, it was necessary to prove that it is directed to service users in the territory of the Republic of Poland. From 1 June 2021, the "availability" of the domain to users located in Poland is sufficient ground for entering the domain into the Register. Also, according to the abovementioned amendment, not only will the names of Internet domains used to organise gambling contrary to the provisions of the Act be entered in the Register, but also the names of domains used to advertise or promote unlawful gambling available to Internet users located in the territory of the Republic of Poland. Thus, after 1 June 2021 the Register also includes websites that serve to advertise and promote online casinos and gambling games that are not operated in compliance with Polish law, in particular affiliate websites. These regulations also provide for changes in the approval of entries or changes in the Register. Before 1 June 2021, any change in the Register had to be approved by the competent minister for public finance or a secretary of state or undersecretary of state in the office serving the minister for public finance authorised by the minister. In accordance with the Regulation of the Minister of Finance of 23 May 2022, the Opole Customs and Fiscal Office (Opolski Urząd Celno-Skarbowy) has been appointed to deal with matters relating to the Register of domains used to offer gambling in contravention of the Act. After entering the domain into the Register, the domain owner is entitled to file an objection by the competent minister for public finance in order to prove that the entry was groundless. At the same time, according to the additional amendment to Article 15f Section 9, the deadline for considering objections has been extended from 7 to 14 days. As of 16 October 2026, there are approximately 59,000 blacklisted domains. The Register can be found under: https://hazard.mf.gov.pl/ Other enforcement measures that could be taken towards an operator offering unlicensed betting might be following: Criminal sanctions - formal investigation commenced against persons involved in organising betting without a licence, players and persons or entities advertising such betting; and Administrative sanctions - financial penalties.