UOKiK’s 2025 annual report: record fines, personal liability and new enforcement frontiers

Following a record year in 2025, the Polish Office of Competition and Consumer Protection (UOKiK) has published its annual report for 2025, demonstrating an unprecedented level of enforcement activity. With more than PLN 1.15 billion (approximately EUR 267 million) in fines imposed across 900 decisions, the authority has sent a clear message: competition and consumer protection enforcement in Poland is entering a new, more assertive phase.

Against this backdrop, several key trends are particularly relevant for compliance officers and management boards operating in Poland. UOKiK is increasingly targeting individuals in management positions, expanding its scrutiny of the labour market (including no-poach arrangements) and actively pursuing greenwashing and e-commerce infringements.

Experience from our practice and the 2025 report highlights the following critical areas of risk:

1. Personal liability of managers is no longer theoretical

UOKiK has made the personal liability of management a clear enforcement priority. In 2025, the President of UOKiK imposed fines totalling PLN 1.4 million directly on individuals in management positions, including PLN 562,000 for competition-restricting practices and PLN 600,000 for infringements of collective consumer interests.

The courts are supporting this approach. In 2025, the Court of Appeal upheld a landmark decision concerning a cartel in the fitness sector, confirming fines not only for the companies involved but also for their managers. In the agricultural machinery sector, another high-profile case resulted in combined fines of PLN 339 million imposed on both the companies and their executives.

For management boards, the message is clear: a lack of awareness of subordinates’ actions does not shield executives from personal financial liability. Robust compliance programmes are now essential to mitigate individual exposure and protect the organisation.

2. Antitrust enforcement enters the HR department

The 2025 report confirms a trend observed across Europe: the labour market is now firmly within the scope of antitrust enforcement.

One of the most prominent cases involved charges brought against the owner of the Biedronka retail chain, 32 transport companies and eight managers. The investigation concerns an alleged no-poach arrangement designed to restrict the movement of drivers between transport companies servicing the retailer’s distribution centres.

This trend was strongly emphasised during European Competition Day, hosted by UOKiK in 2025 as part of Poland’s presidency of the Council of the EU. Companies should be aware that B2B contracts, co-operation agreements and even informal HR policies on recruitment may be treated as unlawful market coordination, exposing them to fines of up to 10% of the undertaking’s turnover in the preceding financial year.

3. The end of tolerance for greenwashing

As sustainability claims increasingly influence consumer behaviour, misleading environmental marketing is becoming significantly more costly. In 2025, UOKiK moved beyond warnings and began taking direct enforcement action against greenwashing practices.

The authority brought its first charges for pseudo-ecological marketing against major players in the e-commerce and logistics sectors, including Allegro, DHL, DPD and InPost. It challenged claims that services were “climate neutral” or “zero-emission”, finding that such statements were based on incomplete data or applied only to limited parts of the businesses concerned.

With the EU’s Empowering Consumers Directive (2024/825) due to apply from September 2026, marketing and PR departments will need to fundamentally reassess their approach. Environmental claim must be supported by reliable and verifiable evidence to avoid significant financial penalties and reputational damage.

4. E-commerce and AI under close scrutiny

Digital markets remain a high-risk area. UOKiK has developed sophisticated tools for monitoring online commerce and has imposed multi-million-zloty fines for misleading practices.

In 2025, a major fashion platform (Zalando) was fined nearly PLN 31 million for failing to display the lowest price applied in the 30 days preceding a discount, in breach of the Omnibus Directive. Another platform operator (Temu) received a fine of almost PLN 6 million for similar infringements.

UOKiK is also examining the impact of new technologies. It has brought abuse-of-dominance charges against Apple in relation to its App Tracking Transparency framework and is actively participating in international initiatives focused on the use of AI in law enforcement. E-commerce interfaces, pricing algorithms and privacy policies should therefore be designed with compliance in mind, particularly to avoid so-called dark patterns.

5. Payment backlogs: as a persistent compliance risk

Liquidity management remains a key enforcement area. In 2025, UOKiK analysed nearly four million invoices and identified payment backlogs exceeding PLN 881 million. This led to 29 decisions and fines totalling more than PLN 10 million, primarily in the automotive, machinery and food sectors.

Notably, UOKiK also issued 177 so-called soft warnings. More than 90% of the companies provided explanations and approximately half permanently improved their payment practices, thereby avoiding formal proceedings. Payment discipline is no longer only a commercial concern but a strict legal requirement.

6. How we can help

We provide comprehensive legal adice on competition and consumer protection compliance, enforcement and related regulatory matters. Our team supports businesses in navigating complex regulatory environments and complying with both existing and upcoming requirements.

We recommend that companies:

• conduct targeted compliance audits, with particular focus on HR practices (including no-poach clauses), environmental marketing claims and e-commerce pricing practices;
• implement or update management training programmes to mitigate the growin grisk of personal financial liability for executives; and
• review payment processes to ensure compliance with statutory deadlines and minimise exposure to UOKiK enforcement.