The Omnibus Directive has applied in Poland since 1 January 2023. It introduces specific duties for online stores, brick-and-mortar shops and e-commerce platforms in four areas: showing prices during price reductions, explaining how offers are ranked, disclosing individualized prices and verifying customer reviews. Failure to comply can result in penalties of up to PLN 20,000 from the Trade Inspection or as much as PLN 2 million for individualized pricing. The rules and implementation steps are set out below.
What the Omnibus changes cover and whom they apply to
The Omnibus Directive required amendments to four acts:
- Consumer Rights Act
- Act on Counteracting Unfair Market Practices
- Competition and Consumer Protection Act
- Act on Informing on Prices of Goods and Services
The changes apply to:
- online stores (e-commerce),
- brick-and-mortar shops,
- marketplaces and e-commerce platforms,
- marketing campaigns and advertisements that show a price.
This is not just a matter of updating terms and conditions. The way information is presented on a website, in an offer and in an advertisement must also change.
When the Omnibus Directive took effect
The provisions implementing the Omnibus Directive in Poland took effect on 1 January 2023. Every online and brick-and-mortar store should already have adjusted its terms and conditions, customer-service procedures and price displays.
Price reductions: an end to artificial promotions
Raising a price before a sale so that a discount can later appear more attractive is a practice the Omnibus Directive is intended to end.
How to show a price reduction correctly
Three rules apply, depending on the situation:
- A product sold for more than 30 days: next to the reduced price, show the lowest price from the 30 days before the reduction was introduced.
- A product sold for less than 30 days: next to the reduced price, show the lowest price from the start of sales until the reduction was introduced.
- A perishable product or one with a short use-by date: next to the reduced price, show the price that applied before the first reduction.
The detailed rules for displaying prices and exceptions are set out in a regulation issued by the minister responsible for the economy.
Where you must apply these rules
- On the online store’s website
- In a brick-and-mortar store, on labels and signs
- In advertisements for goods and services when they include a price
Penalties for breaching the price-reduction rules
| Violation | Penalty |
|---|---|
| First violation | up to PLN 20,000 (imposed by the provincial inspector of the Trade Inspection) |
| Another violation within 12 months | up to PLN 40,000 |
Duties of e-commerce platforms and marketplaces
If you operate a marketplace or an e-commerce platform, you must meet additional requirements.
What you must tell the buyer
- The seller’s status: whether the seller is a business or a private individual. This affects the consumer’s right to withdraw from the contract within 14 days. Failing to provide this information is an unfair commercial practice.
- How responsibilities are divided: clearly specify who is responsible for what, the seller or the platform. Consumers must know whom to contact with a complaint and on what terms.
Where to display this information
Putting this information only in the terms and conditions is not enough. Consider how to show it directly in the product offer, where consumers make their purchase decision.
Offer rankings: an end to fictional rankings
Platforms previously presented products as ranked by popularity or ranking, when in reality an offer’s position depended on the fee paid by the seller. The Omnibus Directive requires transparency.
What you must disclose
- The main parameters that determine the order in which offers appear, such as price, rating, date added or promotion fee.
- The relative importance of each parameter: consumers must know which parameter carries more weight.
How to do this correctly
- Information must be concise, understandable and displayed prominently, not only in the terms and conditions.
- You do not have to disclose the algorithm or detailed ranking mechanisms. It is enough to identify the main parameters and how they affect results.
- Paid promotion is not prohibited, but you must tell consumers when an offer is promoted for a fee.
Individualized prices: a disclosure duty
If your store uses automated decision-making and profiling of customer behavior to set prices, you must inform consumers.
The mechanism and risk
Profiling can be used to assess a consumer’s purchasing power and offer them a higher price. The Omnibus Directive does not prohibit this practice, but it requires transparency.
What you must do
- Before an order is placed, tell the consumer that the proposed price was individualized based on collected data about their preferences.
- The information must appear before the consumer makes a purchase decision, not afterwards.
Penalty for failing to disclose
The penalty may be as high as PLN 2,000,000. The Trade Inspection conducts checks in this area.
Product reviews: verification and no manipulation
The Omnibus Directive addresses three practices involving reviews:
- Fake reviews: publishing reviews by people who have not bought or used the product is an unfair commercial practice.
- Failure to verify the source of reviews: if you allow reviews, you must state whether and how you verify that a review comes from an actual buyer. Failure to verify may result in sanctions.
- Commissioning fake reviews: publishing or commissioning false reviews and recommendations is illegal.
What to implement in your store
- Introduce a review-verification mechanism, such as purchase confirmation.
- Explain on your website how you verify that reviews are authentic.
- Do not selectively remove negative reviews or add positive ones without verification.
Omnibus Directive implementation checklist
Check whether your store meets the following requirements:
- Prices during reductions: each reduction displays the lowest price from the previous 30 days, or from the start of sales.
- Advertisements showing a price: advertisements for reductions also show the reference price.
- Seller status on a marketplace: consumers know whether they are buying from a business or a private individual.
- Division of responsibilities between platform and seller: clearly stated in the offer, not only in the terms and conditions.
- Offer-ranking rules: ranking parameters and their relative weight are described, and paid promotion is disclosed.
- Individualized prices: if you use price profiling, consumers are informed before purchase.
- Review verification: a mechanism confirms that reviews come from buyers, and the verification method is described on the website.
- Terms and documentation: updated to reflect all the changes above.
If any of these requirements is not met, adjust your procedures and documents. The penalties are real, and the Trade Inspection conducts active inspections.
Need help with implementation? Write to us. We can help organize the documentation and processes.
Updated: April 2026
Frequently asked questions
How should an online store display a price reduction under the Omnibus Directive? For each price reduction, show next to the promotional price the lowest price from the 30 days before the reduction was introduced. If a product has been sold for less than 30 days, show the lowest price from the start of sales until the reduction was introduced. The same rules apply on the store’s website, in a brick-and-mortar store and in every advertisement that shows a price. A first violation can result in a fine of up to PLN 20,000, and a further violation within 12 months can result in a fine of up to PLN 40,000.
Is it enough to put the required information in the terms and conditions to meet the Omnibus duties on a marketplace or e-commerce platform? No. Putting information only in the terms and conditions is not enough. You must show the seller’s status, business or private individual, and the division of responsibilities between the platform and seller directly in the product offer, where the consumer makes the purchase decision. Failing to disclose seller status is classified as an unfair commercial practice.
What must a sales platform disclose about offer rankings and paid product promotion? The platform must identify the main parameters that determine the order in which offers appear, such as price, rating, date added or promotion fee, and explain their relative importance. Consumers must know which parameter carries more weight. Paid promotion is not prohibited, but consumers must be told when an offer is promoted for a fee. The algorithm does not have to be disclosed. A concise, understandable notice in a prominent place is enough; it should not appear only in the terms and conditions.
When must customers be told that a price has been individualized, and what penalty may apply? If your store uses automated profiling of customer behavior to set prices, you must tell the consumer about the individualized price before an order is placed, not afterwards. The penalty for failing to provide this information may be as high as PLN 2,000,000, and the Trade Inspection conducts checks.
How should a store verify customer reviews under the Omnibus Directive? Introduce a review-verification mechanism, such as purchase confirmation, and explain on the store’s website how you check that a review comes from an actual buyer. Publishing reviews by people who have not bought the product and commissioning fake reviews are unfair commercial practices subject to sanctions. Do not selectively remove negative reviews or add positive ones without verification.
