UOKiK fines: more show than revenue?

Headlines about multimillion-zloty fines suggest a booming revenue stream for Poland’s state budget. In reality, legal appeals, court reductions, and enforcement delays mean most fines never reach their full announced value.

Between 2021 and 2025, Poland’s Office of Competition and Consumer Protection (UOKiK) imposed fines on companies totaling more than PLN 3.6 billion (around EUR 840 million). Only a portion of that sum has actually reached the state budget. We examine how the appeals process works, what determines whether sanctions are reduced, and how often businesses prevail against the authority in court.

This is an updated version of a text we originally published before UOKiK released its data for 2025. The present version covers data on fines imposed and payments made by sanctioned entities in the years 2021–2025.

“UOKiK hits a company with a multimillion-zloty fine.” Repeated across the media, such eye-catching headlines from the authority may suggest that the state budget is being generously replenished solely through penalties for breaches of competition rules or for unfair practices harming consumers. In practice, however, many of the cases initiated by the authority are discontinued at subsequent stages, or the level of fines is reduced. This is confirmed both by conversations with lawyers representing businesses and by the authority’s own annual reports.

UOKiK fines in numbers

How many decisions ultimately result in an effective (final and binding) penalty in the amount originally imposed by UOKiK? This remains unclear. As recently as January, we asked UOKiK for data on the subsequent “fate” of non-final decisions. The authority has not responded.

The scale of the issue is suggested by figures published in UOKiK’s annual reports (with data for 2025 taken from a UOKiK press release). In the years 2021–2025, the total value of fines imposed by the president of UOKiK on dishonest businesses exceeded PLN 3.6 billion (about EUR 840 million). Over the same period, the amount actually paid totaled PLN 909.4 million (roughly EUR 212 million).

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Pełny ekran

Where do these discrepancies come from? Of course, one must bear in mind that in some cases – as discussed below using specific examples – years can pass between the issuance of a decision and the effective payment of a fine. Still, the figures cited may also point to the limited effectiveness of penalties whose imposition is announced by the president of UOKiK.

Kacper Pomian, an attorney-at-law at J. Dauman Legal, explains that UOKiK deliberately imposes severe fines. Their purpose, he says, is to serve as a deterrent – a “scarecrow” – for other market participants.

“The message to the market matters”

Our interlocutor points to the role played by UOKiK.

“The primary and fundamental task of UOKiK is market supervision, in its capacity as the authority for competition and consumer protection. From that perspective, what matters is the message sent to other market participants – that the fines imposed by UOKiK are severe. The penalties are meant to deter other companies from entering into anticompetitive agreements or from infringing collective consumer interests,” explains Kacper Pomian.

As he adds, if the fines imposed by UOKiK were merely symbolic, many large companies would be able to “expense them” and accept the risk as a cost of doing business. UOKiK’s penalties therefore serve a warning function for others. At the same time, the consequences are severe enough that companies choose to appeal. The cost of a court battle is relatively small compared with the fines imposed. Appealing a UOKiK decision may consume not only money but also time, as such cases can drag on for years.

From a UOKiK decision to a final judgment - a long road

“Judicial review often leads to a reduction of the fines imposed by the president of Urząd Ochrony Konkurencji i Konsumentów. The court has full authority to assess whether the penalty imposed is proportionate to the infringement found,” explains Jakub Sadurski, an attorney at Affre i Wspólnicy sp. k.. A court battle, however, can drag on for years.

The expert explains how the procedure works:

• First, the president of UOKiK concludes the administrative proceedings by issuing a decision. In that decision, the authority may find an infringement of the law and impose a fine. There are also cases that end with a decision of a different kind – UOKiK does not impose a fine but instead accepts certain commitments from the company to change its practices. For the purposes of this discussion, however, let us focus on the former scenario.
• A company may appeal a fining decision issued by the president of UOKiK to the OKIK court (SOKiK), a specialized division of the Warsaw Regional Court.

The case goes to court

As Jakub Sadurski explains, proceedings before the court (SOKiK) are a specific form of civil procedure – sometimes described as hybrid in nature. On the one hand, the court hears an appeal against an administrative decision; on the other, it acts as a court of first instance, which means it examines the case in its entirety.

• At this stage, a court fee is payable (PLN 1,000, or about EUR 230). Filing an appeal prevents the decision from becoming final until the court proceedings are concluded. This, in turn, means that the company does not have to pay the fine until the end of the judicial process, and no interest accrues during this “pause.”
• After examining the case, SOKiK issues a judgment – for example, dismissing the appeal. In such a scenario, the company loses the case. If the appeal is upheld, the court may amend or overturn the decision of the UOKiK.
• A company may appeal a SOKiK judgment to the Court of Appeals in Warsaw. As the expert explains, the role of the appellate court is to review the judgment of the lower court. Poland operates under a so-called full-appeal model, meaning the appellate court examines whether the lower court properly established the facts and correctly applied the law.
• If both instances side with the president of UOKiK, or merely reduce the fine, the decision becomes final after the appellate court’s judgment. The company must then pay the fine in the amount set by the president of UOKiK or as modified by the court.
• A cassation appeal to the Supreme Court is still available against the appellate court’s judgment. However, the law treats it as an extraordinary remedy, subject to additional statutory requirements.

New guidelines, tougher fines

Jakub Sadurski notes that in 2024, new guidelines were introduced regarding UOKiK’s penalty policy, specifically in cases involving anticompetitive conduct.

“Applying the guidelines in cases where UOKiK identifies long-standing violations of the law can result in situations where the dominant factor in determining the fine is the duration of the infringement, while other considerations take a back seat. It’s a matter of pure mathematics. Under the guidelines, for violations lasting longer than one year, the base amount is multiplied by the number of full years the company participated in the infringement, as established in the decision imposing the fine,” explains the expert.

Since then, specialists have observed an increase in the ceiling of fines imposed on businesses. Mr. Sadurski adds, however, that courts are not bound by UOKiK’s guidelines and take into account a range of mitigating circumstances.

Why do discrepancies arise between UOKiK fines and final judgments?

Kacper Pomian adds that courts can be more lenient and often reduce fines – but not unconditionally.

“During proceedings, sometimes even after a sanction has been imposed, companies involved in illegal practices can benefit from a leniency program. This works similarly to a ‘crown witness’ system. They can disclose, for example, the details of an anticompetitive agreement and the parties involved. Such conduct and cooperation with the authorities may protect a company from fines or lead to a reduction in the penalty,” explains the attorney.

The result? Discrepancies between the fines imposed by UOKiK and the actual revenues reaching the state budget. The lengthy duration of proceedings and inflation also play a role.

“You also have to consider inflation and general economic growth. Companies fined several years ago would likely face higher fines today due to increased turnover. Court cases often take several years. That is why outstanding payments may not match the value of fines imposed in the current year,” Kacper Pomian concludes.

Małgorzata Zawadzka, an attorney at Kancelaria Hantke&Piskor, points to another factor that can prolong the process: enforcement.

“Even after a decision or court judgment becomes final, there is the stage of administrative enforcement. If voluntary payment is not made, enforcement proceedings may need to be initiated, which also takes time. Additionally, companies can request that the fine be paid in installments or that the payment deadline be postponed, which can further delay the actual transfer of funds – sometimes by several years,” explains the expert.

Fines versus actual revenues: market examples

Polmass. In 2021, the president of UOKiK, Tomasz Chróstny, found that the market for animal feed producers was subject to a collusion that restricted farmers’ and milk-replacer sellers’ freedom of choice. He imposed a fine of PLN 2.5 million (around EUR 580,000) on Polmass. Polmass S.A. reports that, after five years, the decision is still not final; the company has appealed and is still awaiting the court’s ruling.

Eurocash. In the same year, UOKiK imposed a fine exceeding PLN 76 million (about EUR 17.7 million) on Eurocash for unfair exploitation of a bargaining advantage. President Chróstny stated that suppliers of agricultural and food products to the company’s stores were required to bear numerous additional and unjustified fees.

Eurocash’s press office reports that the company appealed to the OkiK court. By the judgment of February 19, 2024, the Warsaw Competition and Consumer Protection Court fully annulled UOKiK’s decision. The president of UOKiK appealed, but the appeal was dismissed by the Warsaw Court of Appeals on January 27, 2026.

The OKiK court ruling is now final, and the 2021 decision of the president of UOKiK has been definitively overturned.

Are fines a measure of UOKiK’s effectiveness?

In 2024, the president of UOKIK issued a decision regarding an unlawful agreement between KIA Poland and its car dealers. According to the authority, the companies colluded on car prices and divided the market. Twelve companies and five individuals were fined a total of PLN 408 million (around EUR 95 million).

The case has not yet been concluded.

“Kia Poland does not agree with the allegations and findings made by the president of UOKiK and is defending itself using all available legal means. Currently, the case is at the stage of reviewing the appeal in court,” says Monika Krzesak, PR manager at Kia.

This raises the question: can the size of fines alone serve as a sufficient measure of UOKiK’s effectiveness? Experts say: not necessarily.

“From the perspective of the market as a whole, what matters most is whether UOKiK’s actions lead to clear standards of conduct. The key point is not just that the market knows the authority imposes severe fines. The essential issue is that everyone understands which practices and behaviors can trigger those fines – and that there is a sense among market participants that violators will face sanctions. It ensures that companies who ‘play fair’ are not competitively disadvantaged compared with those who break the law and face no regulatory response,” explains Jakub Sadurski.

Moreover, the competition and consumer protection system is not based solely on financial penalties.

“In many cases, the primary objective is to change market practices, not just to achieve a financial penalty. As a result, the nominal value of imposed sanctions should not be the only metric of the authority’s effectiveness. On the contrary, the number of proceedings conducted can indicate its level of supervisory activity in both consumer rights and competition,” adds Małgorzata Zawadzka.

2026 could be a record year – thanks to Gazprom

After the publication of our article, UOKiK released its statistics for 2025: 900 decisions and fines totaling over PLN 1.15 billion (around EUR 267 million).

“It was a year of decisive action – both against unfair market practices and collusion limiting competition. I imposed more than a billion zlotys in sanctions on companies violating the law. But our work is not just about fines; it also drives real changes in business practices and ensures fair compensation for customers. We are building a market where transparency, fairness, and level playing fields prevail. We make sure that in dealings with companies, consumers are not the weaker party,” emphasizes Tomasz Chróstny, president of UOKiK.

And what about actual payments? Last year, PLN 307 million (around EUR 71 million) reached the state budget. The authority notes that this figure may rise in 2026, as enforcement proceedings have begun in connection with a record fine imposed on Gazprom. The Russian company failed to provide information during ongoing proceedings regarding financing of the Nord Stream 2 gas pipeline without the required consent of the president of UOKiK. Gazprom is required to pay PLN 174 million (about EUR 40 million).

Key Takeaways

1. Kacper Pomian, attorney-at-law at J. Dauman Legal, explains that the primary and fundamental task of UOKiK is market supervision, in its role as the authority for competition and consumer protection. According to the expert, what matters is the message sent to other market participants – that fines imposed by UOKiK are substantial. The penalties themselves are intended to deter other companies from entering into anticompetitive agreements or infringing collective consumer interests.
2. “UOKiK hits a company with a multimillion-zloty fine.” Repeated across the media, such eye-catching headlines from the authority may suggest that the state budget is being generously replenished solely through penalties for breaches of competition rules or for unfair practices harming consumers. In practice, however, many cases initiated by UOKiK are discontinued at subsequent stages, or the fines are reduced on appeal.
3. Between 2021 and 2025, the total value of fines imposed by the president of UOKiK on dishonest businesses exceeded PLN 3.6 billion (around EUR 840 million). During the same period, the amount actually paid totaled PLN 909.4 million (approximately EUR 212 million).