Poland’s Office of Competition and Consumer Protection (UOKiK) has opened explanatory proceedings into seven licensed bookmakers, examining whether their websites, apps and contract terms push customers to bet more often and make it harder to stop.
The operators named are STS, Fortuna Online Zakłady Bukmacherskie, Superbet Zakłady Bukmacherskie, Bukmacherska, which runs fuksiarz.pl, E-toto Zakłady Bukmacherskie, LV Bet Zakłady Bukmacherskie and Totalbet Zakłady Bukmacherskie. The review, announced on 24 August, covers the full customer-facing side of each business: websites, mobile applications, communications with users and the terms and conditions that govern player accounts.
Explanatory proceedings are directed at a market rather than at a named company, and no charges have been brought on that track. The contract terms strand is further along: alongside the market review, UOKiK has opened separate proceedings over prohibited contract terms against five of the seven. If it opens proceedings over practices infringing collective consumer interests and finds a breach, it can impose a fine of up to 10% of an operator’s turnover in the preceding financial year. The same ceiling applies to a finding on prohibited contract terms.
AI used to flag dark patterns
UOKiK said it will use an artificial intelligence tool built for the exercise to identify potential shortcomings across the seven operators’ interfaces. The office has not disclosed how the tool works, what criteria it applies or how its findings are checked before they reach case handlers.
The target is what regulators call dark patterns: interface design, wording or incentives that steer a user toward a decision they would not otherwise take. In betting products that usually means default settings, countdowns, bonus mechanics and prompts that appear at the point where a customer is about to stop or withdraw.
Account closure and the asymmetry test
Player protection is the second strand. UOKiK is looking at how easily a customer can step away, including permanent account closure and temporary suspension, and whether the path out of a product is as short as the path back in.
That asymmetry is the specific point at issue. Reopening a closed account is often a single click, while closing one can require a written request, a support conversation or a cooling-off flow that offers a bonus first. Where UOKiK finds that gap, it can treat the design as a practice that obstructs a consumer’s ability to exercise a right rather than as a customer service problem.
Contract terms and disputes over winnings
The third strand is the balance of rights written into operator terms, and it is the one where UOKiK has already moved past the exploratory stage. Five of the seven face separate proceedings over prohibited contract terms: STS, Fortuna Online, Superbet, Bukmacherska and E-toto. Unlike the market review, those cases name the companies from the outset.
UOKiK will assess whether the rules on cancelling deposits, restricting betting limits, blocking accounts and settling disputes over winnings are clear and applied evenly, or whether they give the operator discretion the customer does not have. The regulator’s position is that a customer has to be able to tell in advance which circumstances trigger those decisions and what follows from them.
Clauses of that type carry their own risk in Poland. Terms found to be abusive can be struck out of consumer contracts by the courts and by the regulator, leaving the rest of the agreement in force and the operator unable to rely on the provision it wrote.
“Mutual betting is a legal form of entertainment, but the gambling market is covered by special regulations with the goal of counteracting addiction, the consequences of which can affect not only personal finances, but also family life and consumer health. Businesses operating in the market should be expected not to use practices that may increase the risk of compulsive and harmful behaviour and to provide mechanisms to allow players to stop gambling,” said Tomasz Chróstny, President of UOKiK.
What it means for the Polish market
Sports betting is the vertical Poland opened to private licensees, which is why a consumer review of this kind lands on bookmakers first. Online casino remains far tighter, with the state monopoly joined only recently by a second legal online casino, so the seven names under review account for most of the licensed online gambling activity Polish consumers see.
The review also lines up with where consumer regulators across central Europe are pointing. The Slovak regulator has moved on product design aimed at younger users, and the same questions about defaults, prompts and exit routes are being asked in several markets at once.
UOKiK has described the checks as routine and has not set a deadline for findings. What follows depends on what the review returns: either it closes without action, or it converts into formal proceedings against individual operators, at which point the 10% turnover ceiling and the cost of rewriting terms and interfaces stop being theoretical. For the five already facing contract terms cases, that point has arrived.
Source: Office of Competition and Consumer Protection (UOKiK)
