POLISH REGULATION
In October 2024, the Department of Gambling Market Regulation and Gambling Tax was established. It is responsible for regulating the gambling market, granting licenses, approving rules for games under the state monopoly, and issuing decisions defining the nature of games. It also handles technical inspections and international cooperation. The department is expected to closely monitor the rapidly growing online grey market. Similar departments existed in the past but were dissolved nearly eight years ago. A new Interministerial Team for Combating the Grey Market was also formed and its inaugural meeting took place on April 14, 2025, at the Ministry of Finance. This team coordinates government actions against the grey market and was established following International Monetary Fund (IMF) recommendations. Representatives of the European Commission also participated. The project “Improve the capacity of Poland to better assess and counteract the grey economy” is being implemented in cooperation with the IMF. The government has reopened discussions on changes in the gambling industry. On March 27, 2025, a meeting of the Parliamentary Team for the Free Market was held as part of these discussions, focusing on illegal gambling in Poland, diagnosing the problems in combating it and proposing solutions. As a participant in the meeting, I can confirm that the discussion was very substantive, the industry representatives shared common goals, and this is a strong motivation for cooperation on potential changes. These new institutions present an opportunity for legal reform. However, tangible effects of their work have yet to be seen, likely due to the short time since their establishment.
Council of the European Union. One of its initiatives is to establish a special task force under the European Commission to more effectively combat illegal gambling. This is seen as essential given the diversity of gambling laws across EU member states. The EU has repeatedly emphasized that each country may establish its own gambling regulations due to the sector’s specific nature and the need to protect public health. However, common AML (Anti-Money Laundering) regulations show that the EU is beginning to harmonize gambling-related rules. The 6th AML Directive, for instance, requires all gambling service providers to be regulated and supervised. 6 Given the EU’s ability to issue binding principles on gambling regulation, harmonized efforts to combat illegal online gambling should be feasible – especially considering the estimated €7.2 billion annual loss in unpaid taxes due to illegal gambling and the EU’s focus on money laundering prevention. The proposed task force would include experts from member states and serve as a platform for exchanging experience, knowledge, and best practices in gambling regulation and enforcement. Special emphasis would be placed on using AI technologies to identify and eliminate illegal gambling websites. 7 An issue highlighted in the discussions was the legality of loot boxes – virtual boxes in video games containing randomized rewards, some of which may be worth up to €117,000 on the secondary market. They resemble gambling in their mechanics, yet in some countries, they are not classified as such, creating the potential for abuse. This issue is not unique to Poland and has been debated across the EU. Poland initiated the topic at Council of Europe meetings, receiving a positive response from the European Commission. The matter is under further examination. 8 This initiative is valuable and should be supported by other member states and gambling organizations.
Poland’s European Union presidency
On January 1, 2025, Poland assumed the presidency of the
6 Directive 2024/1640 on the mechanisms that Member States should implement to prevent the use of the financial system for money laundering or terrorist financing, amending Directive (EU) 2019/1937 and amending and repealing Directive (EU) 2015/849. 7 S. Saeed, Poland Proposes EU Group to Tackle Illegal Gambling Revenue, published at: https://news.bloomberglaw.com/daily-tax-report/po- land-proposes-eu-group-to-tackle-illegal-gambling-revenue?utm_source=chatgpt.com, (accessed: May 16, 2025). 8 Statement by the Director of the Department of Gambling Market Regulation and Gambling Tax at the meeting of the Parliamentary Team for the Free Market on March 27, 2025, recording available on the website www.sejm.gov.pl
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IMGL MAGAZINE | JUNE 2025
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