Labour market collusion in Poland's transport sector

On 8 October 2025, the Polish competition authority (Urząd Ochrony Konkurencji i Konsumentów, "UOKiK") announced that after having conducted dawn raids at three companies, it had launched a preliminary investigation into suspected anti-competitive practices affecting driver mobility in the transport sector. 

The suspected anti-competitive mechanism

The case involves alleged "grace periods" or "blockades" that may have prevented drivers from being hired by competing transport companies for a certain period after leaving their previous employer.

According to the authority's preliminary findings, the three transport companies may have implemented a coordinated system of restrictions affecting driver employment. They allegedly agreed not to hire drivers who had recently left competing transport firms, effectively imposing cooling-off periods before workers could join competitors. By preventing drivers from freely moving between employers, the alleged practices may have limited competition for drivers and potentially depressed wages and working conditions.

A novel enforcement approach

Whilst no-poach and wage-fixing agreements have been the focus of recent competition enforcement on labour markets, the concept of collectively enforced "grace periods" may represent a new development in this area.

As traditional labour market collusion cases have typically involved no-poach or wage-fixing agreements, the current investigation differs by targeting a more subtle mechanism; time-based restrictions on hiring that create de facto barriers to worker mobility without explicitly prohibiting recruitment.

This approach potentially extends the scope of competition law enforcement. It recognises that restrictions on when workers can be hired may have similar anti-competitive effects to outright prohibitions on hiring.

The investigation demonstrates UOKiK's commitment to protecting competition on labour markets and ensuring that workers retain the freedom to move between employers without artificial barriers imposed by means of anti-competitive coordination.

Legal framework and penalties

Agreements that restrict competition on labour markets constitute serious violations under Polish and EU competition law. Such practices harm workers by limiting their employment options and may depress wages and working conditions.

Companies found guilty of participating in agreements that restrict competition face possible fines of up to 10% of their annual turnover, whilst individual managers responsible for cartel participation can be fined up to PLN 2 million.

If you need more information or further guidance in this area,  please contact Marcin Alberski and Stanislaw Szymanek.

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