Dr Justyna Grusza-Głębicka, Attorney at Law and specialist in Polish iGaming law, takes a look back at a year of legislative developments affecting Poland’s iGaming space…
Anyone working in the gambling sector in Poland rarely laughs at the circus. How can we summarise 2025 in terms of any legislative wins for Polish gambling? Great hopes always lead to great disappointments, as we should all know better!
The year 2025 began with intense discussions involving representatives of the industry and the government. Everyone agrees on the need to combat the ‘grey market’ and the need to protect minors.
This mandate created hope for real progress towards liberalisation, especially in the online casino segment. The year ended, however, with a fiscal tightening of the legal part of the market through an increase in tax on winnings…
Let’s take a closer look at the year’s developments, step by step.
The Specificity of the Polish gambling Market
To begin with, let me recall that in Poland, unlike in many other countries, there is a state monopoly in the online casino segment, operated by the state-owned company Totalizator Sportowy. The betting sector operates under a licensing model, but with a crucial caveat: a 12% turnover tax, rather than GGR (gross gaming revenue), which is the standard in most jurisdictions.
Real poker can be played only in land-based casinos. Land-based casinos require a concession licence, and the market is strictly limited. As for lotteries – these may be promotional, audio-text or charity lotteries, most other lottery formats are within the monopoly, similarly to the online casino.
Poland’s biggest challenge is the black market / grey economy. Or perhaps this is the main challenge for the entire global iGaming sector?
Here are some figures from the state monopoly model, presented in the report “The Last Monopoly of its Kind in Europe” by the Warsaw Enterprise Institute (WEI):
- approx. 40.9% of the online casino market belongs to entities operating in the grey zone,
- in 2023, 83% of players used illegal online casino services,
- in 2023, the turnover of illegal online casinos amounted to PLN 26 billion,
- the estimated value of the grey market in 2024 may reach PLN 25.9 billion,
- the state budget lost approx. PLN 519 million in 2023 due to unpaid taxes.
According to data developed by EY and published by the “Graj Legalnie” association, channelisation in Poland is approx. 76% for the betting market and only 59% for the online casino market.
Looking at these numbers, all one can say is: there is much to be done.
New Institutions, New Opportunities
The gambling industry has long argued for the need to create a dedicated regulatory body focused exclusively on gambling. Currently, market oversight is exercised by the Minister of Finance. At the end of 2024, Poland established the Department for Market Regulation of Games and Gaming Tax. Although it is not equivalent to the UK Gambling Commission, there was hope that separating this department would enable real change for all participants in the legal market. The department was expected to monitor the sector closely, especially the expanding grey market and to cooperate with regulators from other jurisdictions and international organisations.
On 1 January 2025, Poland assumed the Presidency of the Council of the European Union. One of Poland’s initiatives was the proposal to establish a special working group under the European Commission that would help effectively combat illegal gambling. This group would consist of experts from EU Member States and function as a platform for the exchange of knowledge, experience and best practices in regulating and enforcing gambling laws. Considering the wide variety of regulatory frameworks across the EU, such action appears well justified.
In March, the government established an Interministerial Task Force for Combating the Grey Market. The inaugural meeting took place on 14 April 2025 at the Ministry of Finance. The task force was created to coordinate government action in combating the grey market and was a response to recommendations from the International Monetary Fund. Representatives of the European Commission also participated in this meeting.
On 27 March 2025, a meeting of the Parliamentary Team for the Free Market was held, focused on illegal gambling in Poland, identifying challenges in combating it and discussing proposed solutions. As a participant, I can confirm that it was a very substantive debate, industry representatives expressed shared goals, and the discussion was a strong motivation for collaboration on potential changes.
Poker Still Stuck “in the Drawer”
Also in March, MP Przemysław Wipler (Confederation party) announced a bill to legalise poker in Poland. The main argument is that poker is a skill-based game, not a game of chance. However, expectations were quickly dampened – there is no parliamentary majority to support the reform under the current government. The proposal therefore remains “in the drawer,” and any liberalisation before the 2027 elections is unlikely.
Enforcing Regulations on Payment Institutions
The grey market remains strong, and legislative change has not materialised. The industry therefore decided to make use of the tools already available. An important step was taken to push payment service providers towards cooperation exclusively with the legal part of the gambling market.
Since 2017, Poland has prohibited payment service providers (PSPs) from offering payment services on websites whose domain names are listed in the Register of Domains Used to Offer Gambling in Violation of the Law. PSPs must block such services within 30 days of a domain being added to the Register. Despite this, many payment providers continued to serve offshore casino sites targeting Polish users.
At the European Financial Congress held in Sopot in June, discussions included the financial sector and the grey gambling market. Leading representatives of the gambling and financial industries participated, including representatives of the Polish Financial Supervision Authority (KNF). A proposal was presented to establish a task force to combat fund transfers to illegal operators.
Shortly afterwards, a debate emerged on LinkedIn revealing that KNF had sent lettersto payment market entities stating that it had identified the involvement of certain PSPs, sometimes in cooperation with other providers, in offering payment services related to organising or promoting illegal online gambling in Poland. KNF requested immediate verification of operations and cessation of such services.
This was a major signal to the entire payments market: even entities without the status of a payment institution may face responsibility, including administrative, criminal, or fiscal-criminal liability.
Protecting Minors Online
One of the hottest topics of 2025 has been loot boxes. The video-gaming industry continues to rely on randomised reward mechanisms which, from both a psychological and regulatory perspective, function in a way similar to a casino. Children are the most vulnerable group of users.
The problem is real. Research indicates that between 39% and 79% of surveyed teenagers participated in gambling activities within the last 12 months (data from NASK – the Scientific and Academic Computer Network).
In August, politicians from the Law and Justice (PiS) party announced a draft bill aimed at protecting minors from online gambling. The bill was expected to reach Parliament in August, but has not yet been formally submitted. According to public statements, the proposal is to introduce a new prohibited-domains system managed by the Minister of Digital Affairs, fast-track administrative fines of up to PLN 1 million, and mandatory age-verification methods (including bank-based identity verification, ID verification or video verification). These changes may enter into force in 2026.
Are loot boxes gambling or not? For a long time, the answer remained unclear. Lawmakers analysed the issue with reference to solutions adopted in Spain, the Netherlands and Belgium, yet for years refrained from introducing hard regulatory measures – until now.
A few days ago, a draft amendment to the Gambling Act was submitted to Parliament by the Chair of the Poland 2050 parliamentary group. The proposal introduces a new category of gambling activities into Polish law: “games for virtual goods”. Organising such games will require obtaining a dedicated licence. The licensing procedure largely resembles that applicable to lotteries and is significantly less complex than the regime governing betting operators. Implementing a responsible-gaming policy will be mandatory, and participation will be limited exclusively to individuals aged 18 and above.
The legislator justifies the amendment by the need to close a regulatory gap and strengthen the protection of minors, who constitute a substantial part of the gaming community and are particularly susceptible to impulsive behaviour and addiction-related risks. It is difficult to disagree with this rationale.
Video game operators – be prepared for change!
Increased Tax on Winnings?
The most significant legal change of 2025 for the gambling sector, although formally outside the Gambling Act, is the increase of tax on winnings. On 14 October 2025, the Council of Ministers adopted a bill amending the Public Health Act and the Personal Income Tax Act, increasing the flat PIT rate on winnings from 10% to 15%. The planned entry into force is 1 January 2026.
In November 2025, the Senate adopted the bill without amendments, the new rate will apply to winnings from competitions, games and betting, including within the EU/EEA. For operators, this may mean reduced attractiveness of winnings from the player’s perspective, the need to modify game mechanics, and a further advantage for offshore operators who do not apply such taxation.
The industry and market have caught a lucky break on this one, however, as President Karol Nawrocki vetoed the proposed tax increase earlier this month – though his decision could still be overruled by two-fifths of the Sejm.
Conclusions
A year has passed, and there is still no visible impact of the new department or the task force on combating the grey market, at least not in a way that the industry can realistically feel.
Poland clearly shows a tendency to strengthen institutional mechanisms to combat the grey market, but without changing the regulatory philosophy – the authorities continue to rely on blocking rather than channelisation. New interministerial teams and increased tax on winnings do not resolve the fundamental problem: the system is still unable to redirect players from the grey market to the licensed market.
Will 2026 be a year of real change? The above analysis suggests that it may instead be a year of increased financial burdens and tightening regulation – the “gambling for children” bill, the entry into force of the increased tax on winnings. I remain optimistic, however. The industry needs to start speaking with ONE VOICE. We have the tools, we have the willingness, but there is a lack of concrete action. That must change.