Poland’s first UOKiK fines for price reductions – what you need to know

The start of 2026 marked a significant development in Poland’s enforcement of the provisions on price reductions introduced by EU Price Indication Directive (PID) (as updated by the EU Omnibus Directive). The Office of Competition and Consumer Protection (UOKiK) has imposed its first fines for improper communication of price reductions on:

• Zalando – approx. PLN 30.95 million (≈ EUR 7.1 million)
• Temu – approx. PLN 5.91 million (≈ EUR 1.35 million)

These fines, totalling nearly PLN 37 million (≈ EUR 8.45 million), send a strong signal to businesses on the importance of fair pricing practices in their dealings with consumers. While detailed reasoning is pending, here are some key insights.

Mandatory disclosure of the “lowest price in 30 days”

Under the PID, any advertised price reduction must include the lowest price applied in the 30 days preceding the discount. UOKiK states that the obligation to provide the lowest price from the 30 days before the reduction applies to all channels (websites, applications, newsletters, social media, as well as external advertising) if the trader communicates a price reduction through them. 

Additionally, under UOKiK’s guidelines on price reductions of May 2023 (Polish version available here), the step of the purchasing journey is also irrelevant. If a trader decides to communicate a reduction from the listing, through the product page, to the checkout, they must provide the lowest price.

An important point to note for businesses operating across multiple jurisdictions is that UOKiK goes beyond the standard interpretation of the PID. Simply showing the lowest price visually (e.g., with a strikethrough) is not considered sufficient. The Polish regulator requires a clear and fairly lengthy descriptive explanation of the lowest price at every stage where the discount is communicated.

This obligation applies regardless of how many prices are displayed and can easily be overlooked, as it does not stem directly from the PID itself or the European Commission’s guidelines on PID. 

Example: In the decision concerning Zalando, UOKiK challenged the lack of information about the lowest price in external ads and product listings.

Manipulation of the lowest price is prohibited

UOKiK challenged the practice whereby a trader provides information about the lowest price and then modifies its value (e.g. changing the lowest price day by day) even though there has been no change to the regular price. In this way, they deliberately create the impression of a greater benefit for the consumer, which is illusory. 

This approach creates a fake perception of greater savings, which is misleading for consumers. The regulator’s focus on this point sends a clear signal: pricing strategies that distort reality are considered unfair commercial practices and may trigger broader and stricter enforcement measures. 

If such practice infringes collective consumer interests, UOKiK can impose significantly higher penalties under unfair commercial practices legislation compared to fines available under the local price-reduction regulations.

Honest use of filters and labels

Further, UOKiK found that using online filters such as "promotions" or "deals" that are based on the initial/regular price, rather than the lowest price from the previous 30 days, also misleads consumers. 

Lack of consistent information about the lowest price

Additionally, following UOKiK’s guidelines on price reductions, UOKiK challenged differences in the way reductions/information about the lowest price are presented in different parts of the platform/website or between the desktop and mobile versions of the site.

Example: Temu provided information about the lowest price only for selected product variants (e.g. for one size), despite the reduction covering the entire product category.

Why should global retailers take note of UOKiK’s recent decisions?

• UOKiK’s decisions are public and widely reported, and enforcement applies even to foreign-based platforms, Temu, owned by Whaleco Technology in Ireland, is a recent example.
• The PID sets uniform transparency obligations across all EU Member States. Poland’s enforcement signals how similar scrutiny may develop elsewhere in the EU.
• If non-compliance is deemed misleading, it may be treated as an unfair commercial practice, exposing businesses to stricter penalties, including fines of up to 10% of annual turnover per violation in Poland.
• These recent cases are only the beginning, with further investigations into major e-commerce players already underway.

Business checklist on fair price reductions practices 

Below is a brief checklist for businesses (basic version whilst awaiting the reasoning behind the decisions): 

• Is the lowest price from the previous 30 days visible in every channel where we communicate a reduction?
• Is the method of presenting the reduction/information about the lowest price (graphics, colours) consistent across different channels (including desktop vs mobile versions) and at individual stages of the purchasing journey?
• Is the information about the lowest price consistent for all product variants (e.g. for all sizes or colour versions – if the promotion covers the entire product category)?
• Are the "promotion" and "deal" filters based on the lowest price from the previous 30 days?
• Does the pricing system prevent manipulation of the lowest price?

For official decision summaries and UOKiK guidance, visit here (in Polish only).