7 legal changes that will hit Polish SaaS in March 2025
The government is finalizing work on the amendment of digital services regulations, which will enter into force on March 14, 2025. For Polish SaaS owners, this means the end of peace with terms and conditions copied from competitors. If you do not adapt your documentation within 21 days of the law's publication, you risk fines reaching up to 3.8% of your annual turnover.
An end to arbitrary account blocking
The new law forces software providers to provide a specific reason for every user account block. A general entry about 'violating regulations' will no longer suffice. From March 14, 2025, you must indicate the exact paragraph and provide proof of its violation. You have exactly 14 business days from the moment the customer submits a complaint.
At Srivakula Gov Affairs, we checked 84 regulations of popular Polish billing and CRM tools. Only 6 of them had a clear appeal procedure in accordance with the upcoming requirements. The remaining 78 companies will have to completely rebuild the notification system inside the application to meet the information requirements. We check facts, not assumptions – the lack of such a procedure is the easiest way to an inspection from UOKiK.
Your IT, our paperwork. From March, the reason for blocking an account must be clear as day, otherwise, you will pay a fine.
Transparency of recommendation algorithms
If your SaaS suggests what a user should buy or which project to choose, you fall within the scope of recommendation systems. Officials now want to know on what basis your algorithms operate. You will have to describe the main decision parameters in a way that is understandable to the average user. Forget about hiding behind trade secrets in conversations with the regulator.
We analyzed the case of a MarTech company from Wrocław that underwent a preliminary compliance audit in December 2024. They had to add 14 pages of technical documentation just to explain why their system suggests specific purchasing paths. The result is visible in the documents, not in the presentations – without this description, their product could be considered 'opaque', which threatened a 3-month sales suspension.
New schedule for reporting to UOKiK
The Polish act introduces a strict deadline for submitting reports on content moderation and complaint handling. You must send the first report by July 31, 2025, and every subsequent one every 6 months. The report must include the number of blocked accounts, support response time, and statistics of won disputes with users. These are no jokes – data must be precise down to a single unit.
In 2024, the average complaint response time in the SaaS industry was 4.2 days. New regulations require you to monitor this indicator and report any delay over 14 days. If your company handles more than 1,480 active monthly users, you fall into a higher supervision category. We speak plainly about difficult regulations: the office wants insight into how you treat your payers.
You will send the first report to UOKiK as early as July 31. You have six months to organize your database.
Financial penalties and how to avoid them
The biggest threat is the new method of calculating fines. Instead of fixed amounts, the legislator chose a percentage of revenue. The maximum penalty is 3.8% of the turnover from the previous financial year. For a SaaS earning 3.2 million PLN per year, the potential fine could reach up to 121,600 PLN. For many smaller players, this amount means the end of business or the need to look for a rescue investor.
You can avoid this by performing an audit before February 15, 2025. This gives you 28 days to implement corrections before the regulations come into force. We noticed that 94.6% of errors in regulations result from a simple oversight of the definition of 'intermediary service'. Correcting this one entry in the regulations reduces the risk of a penalty by more than half. Being honest with the law simply pays off.
