Penalties for Illegal Gambling in Poland: Operators, Intermediaries and Players

Poland backs its restrictive gambling framework with a layered system of sanctions. Operators face administrative fines and criminal liability, but so do the people around them: advertisers, landlords, payment intermediaries and even players. Understanding who is exposed and to what is essential for anyone touching the Polish market. Here is the landscape.

Administrative penalties under the Gambling Act

The Gambling Act empowers the customs and tax administration to impose financial penalties by decision, without the need for a criminal conviction. Organising games without the required concession or permit attracts a fine of a multiple of the tax base or, for slot machines, a fixed amount per machine, currently one hundred thousand zloty each. Advertising gambling in breach of the Act carries a penalty of up to a percentage of the advertising cost, and owners of premises hosting illegal machines face the per-machine fine as well.

Fiscal-penal liability

The Fiscal Penal Code, in Article 107 and related provisions, criminalises organising or running gambling contrary to the Act or a permit. Penalties include fines measured in daily rates, which can reach several million zloty for serious cases, and imprisonment of up to three years for organising illegal gambling. Persons who advertise or promote illegal gambling, and those who make premises or infrastructure available for it, are separately liable. Corporate liability can also arise under the Act on Liability of Collective Entities.

Liability of players

Participating in foreign gambling organised without a Polish permit is itself a fiscal offence under Article 107 of the Code, punishable by a fine. In practice enforcement against individual players has been limited, but the provision exists and has been used, particularly where large sums are involved. Players also lose the tax exemption on winnings from unlicensed operators.

Payment providers and intermediaries

Payment service providers that process transactions to domains listed in the register of prohibited domains face administrative penalties, and individuals facilitating payments for illegal gambling can be liable under the Fiscal Penal Code. Telecommunications providers that fail to block listed domains face their own sanctions.

How enforcement works

The customs and tax administration conducts inspections, test purchases and online monitoring, seizes equipment and cash, and refers criminal matters to prosecutors. Administrative penalties are appealable to the administrative courts; fiscal-penal cases proceed before the criminal courts. Voluntary disclosure and cooperation can mitigate outcomes in some cases.

Practical implications

For international operators, the exposure extends to directors and employees who may travel to Poland, to Polish-resident staff and partners, and to assets in Poland. Treating Poland as a grey market without geo-blocking and marketing controls is a decision with legal consequences well beyond the operator itself.

Our disputes and enforcement team represents operators, suppliers and individuals in administrative and fiscal-penal proceedings.