Regulated
Gambling in Poland is regulated (except for certain provisions on criminal liability and supervision powers), by the Gambling Act of 19 November 2009 (as amended). The Gambling Act applies to “gambling games” which consist of four main categories:

• Games of chance
• Betting
• Card games
• Slot machine games

Games without an element of chance (that is games solely based on the participants’ skill or knowledge) are not subject to the Gambling Act. Based on the last Gambling Act amendments, with respect to gambling games offered in digital form, all online games except for betting and promotion lotteries are subject to state monopoly. The only form of online gambling currently permitted for private entities in Poland (upon the licence or permit granted) are betting and promotion lotteries.

The amendments to the Gambling Act, introduced in 2017, took quite a restrictive approach; therefore, the licensing regime in Poland can be described as severe and uncompromising. The most significant amendment introduced to the system was a monopoly regime over the majority of gambling games, especially offered online; the only online form allowed to be provided by private operators (upon the permit granted) is “mutual betting” (please see the Polish legal definition provided in the General betting overview) and/or a promotion lottery..

Market size
According to estimates by H2 Gambling Capital (H2GC), the total value of the online betting and casino games market in Poland, with unchanged regulatory conditions, will amount to PLN 7 389 million GGR in 2026, while in 2027 this figure will reach PLN 7 923 million.

According to the Ministry of Finance, gambling industry revenues in Poland in 2022 increased by 43.9% compared to 2021. The largest increases were recorded in online casino games (up 50.8%, or PLN 9.31 billion) and gaming on slot machines (up 159.8% or PLN 3.06 billion and mutual betting (up 16.6%, or PLN 1.76 billion).

Competitive landscape
The number of legal operators in the betting market that are licensed by the Minister responsible for public finance to arrange betting is currently 22 operators.

There is also a monopolist in the market, the state-owned company Totalizator Sportowy sp. z o.o., which operates the only legal casino in the Polish market – Total Casino.

Localisation
The Gambling Act allows payment transactions to be carried out only through providers that are: national banks, branches of foreign banks, credit institutions and branches of these institutions, electronic money institutions, payment institutions and cooperative savings and credit unions or the National Cooperative Savings and Credit Fund.

Prominent marketing/advertising channels: Assuming that advertising takes place under the terms of the gambling law, the main advertising channels are radio, television and social media, sport events.

Top Key Attractions and Challenges
Attractions

• Dynamic development of the skill games market
• In the event of doubts about the nature of the game, it is possible to obtain an opinion from the Ministry of Finance regarding the nature of the game
• Fast procedure for obtaining a game opinion – a decision is issued within 1 month
• Dynamic development of the esports industry
• Many foreign operators do not operate on the Polish market but have R&D companies in Poland

Challenges

• State monopoly for the majority of games
• Very limited number of products for which an operator can obtain licences
• Fiscal burdens