Poland: UOKiK's expanding enforcement against resale price maintenance - Early 2026 developments

The Polish competition authority (Urząd Ochrony Konkurencji i Konsumentów, "UOKiK") has announced that it is conducting a preliminary investigation into suspected anti-competitive agreements affecting the sale of electronic equipment. The case involves numerous well-known IT, consumer electronics, and household appliances, including computers, laptops, televisions, washing machines, refrigerators, cookers, vacuum cleaners, and hairdryers.

Following court approval and with police assistance, dawn raids were conducted at the premises of Poland's three largest wholesale distributors of household appliances, consumer electronics, and IT equipment.

According to UOKiK, the investigation has a very broad scope, potentially covering devices from multiple brands. The competition authority is currently analysing extensive evidence gathered during its searches.

The suspected collusion structure

The suspected anti-competitive agreement may have involved businesses at different levels of the distribution chain, including manufacturers and importers, wholesale distributors, and retailers - among them large electronics retailers and online shops.

Such multi-level coordination, if confirmed, would represent a sophisticated anti-competitive scheme designed to control pricing across the entire supply chain, ultimately harming consumers by artificially maintaining higher prices and eliminating genuine price competition.

At present, UOKiK is conducting a preliminary investigation into the matter rather than formal proceedings against specific companies. If the evidence gathered confirms the suspicions, UOKiK will initiate formal anti-monopoly proceedings.

A proven enforcement pattern: Oltens 

 UOKiK recently issued a decision against Oltens 1, a distributor of Oltens-brand bathroom equipment, which for at least several months imposed minimum resale prices on online retailers. Though smaller in scope than the electronics investigation, the Oltens case allegedly involved similar mechanisms of price control and systematic monitoring of retailers.

According to UOKiK’s findings, the company maintained a dual pricing system: whilst its price lists ostensibly contained "suggested retail prices", these were in fact enforced as mandatory minimum prices for online sales. Internal correspondence explicitly stated that "suggested prices are minimum selling prices at which online shops operate".

UOKiK found that Oltens maintained strict monitoring of its partners' online offers using price comparison platforms such as Ceneo. When analysis revealed that a shop was selling even one penny below the prescribed price, or offering free delivery, which was treated as a hidden price reduction, the company's sales representatives would contact the partner and typically give them several days to "correct" their prices.

For repeated violations, Oltens would suspend product deliveries or block the partner's access to its purchasing platform, preventing them from checking inventory and placing orders. Access would be restored only after prices were raised to the level specified by the company.

Partners who consistently adhered to the imposed prices were described as "disciplined" and could participate in promotional campaigns on equal terms with physical showrooms. As one internal email from an Oltens' sales director stated: "Target group: OLTENS showrooms - plus 'disciplined' clients who, in addition to physical showrooms, have online sales - attention, in case of failure to comply with sales policy, clients will be blocked".

UOKiK found that the company violated Polish and EU competition law by establishing minimum resale prices for Oltens bathroom equipment sold online. Such agreements restricted price competition between shops and deprived consumers of the opportunity for genuinely lower prices.

The leniency programme: a critical tool

In the Oltens case, UOKiK applied the leniency programme. Due to the provision of significant evidence and cooperation, penalties for the company and two managers were reduced by 45%. Ultimately, a fine of over PLN 256,000 was imposed on Oltens, while the fines imposed on the company’s managers were significantly lower.

For companies potentially involved in the electronics investigation, the Oltens outcome demonstrates both the consequences of price-fixing and the substantial benefits of early cooperation with UOKiK.

Legal framework and penalties

Agreements that restrict competition constitute serious violations under Polish and EU competition law. Companies found guilty of participating in anti-competitive agreements face possible fines of up to 10% of their annual turnover, whilst individual managers can be fined up to PLN 2 million.

The ongoing investigation into the electronics sector and the Oltens case demonstrate UOKiK's continued commitment to protecting consumer welfare and ensuring that businesses compete on merit rather than through coordinated pricing strategies.

For more details or further guidance in this area, please contact Marcin Alberski or Stanislaw Szymanek.

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