Polish Authority Issues Updated Leniency Guidance Incorporating ECN+ Directive

Warsaw, November 20, 2025 — The Polish Office of Competition and Consumer Protection (UOKiK) has published new guidance explaining how companies and managers can avoid or reduce penalties for participating in anticompetitive agreements by applying to the leniency programme.

The updated explanations reflect legislative changes stemming from the EU’s ECN+ Directive and amendments to Poland’s competition law, as well as the government regulation governing the leniency regime. They replace the previous guidance issued in 2017 and draw on more than two decades of UOKiK’s enforcement experience.

Under Polish law, companies involved in cartels can face fines of up to 10% of annual turnover, while managers responsible for anti-competitive conduct may be fined up to PLN 2 million. The leniency programme allows firms and individuals to avoid or significantly reduce these sanctions if they provide evidence of a prohibited agreement and cooperate fully with the authority.

“Leniency is an important tool that helps us obtain evidence of illegal collusion,” said UOKiK President Tomasz Chróstny. “Companies and managers engaged in cartels should know that coming forward is the best way to avoid severe penalties.”

Since 2015, managers—alongside companies—have been eligible to apply for leniency. In the last five years alone, UOKiK has received more than 30 applications for full immunity or reduced fines.

The new guidance is aimed primarily at lawyers advising firms, but also provides clarity to businesses and executives considering whether to self-report. UOKiK reminded stakeholders that anonymous whistleblowers can also submit information about suspected collusion through a secure platform, which guarantees full confidentiality.

The guidance is available on UOKiK’s website, and a dedicated hotline — 22 55 60 555 — has been set up to answer questions about the leniency system.

Source: https://uokik.gov.pl/jak-uniknac-kary-za-zmowe-prezes-uokik-wydal-wyjasnienia

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