Obligations for entrepreneurs in Poland and the EU
Omnibus Directive
As of January 1, 2023, Poland has been implementing the Omnibus Directive—a regulation that introduces a new level of transparency in pricing, promotions, and consumer reviews. Its purpose is to protect buyers from being misled and eliminate practices that distort market integrity, particularly in e-commerce.
For entrepreneurs, this means the need to correctly present prices, provide information about verifying the authenticity of reviews, and adapt the method of communicating promotions to the requirements of the President of the Office of Competition and Consumer Protection.
What is the Omnibus Directive?
The Omnibus Directive is a set of obligations intended to ensure the reliability of sales and fair information for consumers. It changes the way businesses must present product prices, organize promotions, and manage customer reviews—both in online stores, brick-and-mortar stores, and marketplaces.
The regulation eliminates the possibility of price manipulation before discounts, limits fake reviews, and imposes a requirement for transparent reporting of review origins. As a result, consumers receive accurate information about the product's value and the seller's credibility.
Who does the Omnibus Directive apply to?
The Omnibus Directive imposes obligations on online stores, brick-and-mortar stores, marketplace platforms and all businesses publishing prices, promotions and consumer reviews.
The most important changes – what do online stores need to implement?
Businesses must display the lowest price for a product within 30 days of the discount. This means that each promotion must disclose the actual, historical price level so that customers can assess whether the discount is genuine.
This obligation applies to online stores, brick-and-mortar stores, and marketplaces. All discount messages must be clear, unambiguous, and non-misleading. Increasing or reducing prices just before a promotion is illegal.
Shops and platforms are required to confirm that reviews come from people who actually purchased the product or used the service. The business must indicate how it verifies the authenticity of reviews (e.g., through a post-purchase review system).
It is forbidden to:
- publishing fake reviews,
- removing negative opinions,
- presenting assessments in a selective manner.
This is currently one of the areas most frequently controlled by the Office of Competition and Consumer Protection.
Trading platforms must clearly indicate whether the seller is an entrepreneur or a private individual – because this information determines the scope of consumer rights.
The platform operator should also disclose the rules for ranking offers, including factors influencing the positioning of products in search results.
Why is adapting your store to Omnibus so important?
Credibility-building activities
The introduction of transparent activities is not only a legal obligation, but also a real competitive advantage.
Stores that properly communicate prices and reviews build credibility, increase conversion rates, and minimize the risk of complaints and disputes.
Adapting your store to Omnibus allows you to:
- avoid sanctions and inspections by the Office of Competition and Consumer Protection,
- increase customer confidence in promotions and presented discounts,
- protect yourself against accusations of price manipulation,
- organize the way opinions and assessments are presented,
- improve the transparency of the offer on marketplaces.
Every promotion and every opinion is subject to Omnibus - even minor errors in price presentation may result in sanctions from the Office of Competition and Consumer Protection.
Basic obligations under the Omnibus Directive
The scope of responsibilities depends on whether the store presents prices, reviews, or sells on the marketplace.
What are the penalties for violating the Omnibus Directive?
- - up to PLN 20,000 for violating the rules on price information;
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- up to PLN 40,000 if the violation is repeated three times within 12 months;
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- up to 10% of annual turnover if the action is deemed to violate the collective interests of consumers.
Up to PLN 2 million for members of the management board or management staff if their actions influenced the use of unfair market practices.
- stopping and changing unfair practices,
- removal of the consequences of violations (e.g. refund of unduly collected fees),
- publication of a statement or correction.
Don't wait – ensure the implementation of the Omnibus Directive!
Penalties often involve not only financial consequences, but also a loss of reputation, which in e-commerce has a real impact on sales and customer trust.
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