Poland's EAA Fine Is a Formula — This Year It's 89,035.60 zł
Poland didn't write a number into its accessibility law. It wrote an equation that re-prices itself every February. Here's this year's answer — and why the fine is the least dangerous thing in the Polish act.
Quick answer
Poland's EAA law (the Act of 26 April 2024, Dz.U. 2024 poz. 731) sets no euro figure. The maximum penalty is ten times the average monthly wage in the national economy for the preceding year, and no more than 10% of turnover — the second limb being a cap that lowers the fine for small businesses, not one that raises it for large ones. On the figure published by the Central Statistical Office on 9 February 2026, the 2026 ceiling is 89,035.60 zł — roughly €21,000. But two other provisions matter far more: a regulator can ban you from providing the service for 180 days, and an ignored consumer complaint is automatically deemed decided against you.
A law with no number in it
Poland belongs to a very small group — with Italy on one side and Spain on the other — where "what's the fine?" has no fixed answer. The difference is that Poland's answer is computable. The statute names an index, and the index is republished annually, so the ceiling moves every year without anyone amending the law.
Two consequences worth stating plainly. First, every published figure for Poland has a shelf life of twelve months; most of the ones circulating are two indexations out of date. Second — and this is the part the comparison tables get backwards — the turnover element is not a route to a bigger fine. Read the wording: the penalty is capped at ten times the wage figure and at 10% of turnover, whichever is lower. For any business turning over more than about 890,000 zł (~€209,000), the wage limb binds. The 10% only bites on the very smallest operators, where it pulls the maximum down.
| Your annual turnover | Which limit applies | 2026 maximum |
|---|---|---|
| Above | 10 × average monthly wage | 89,035.60 zł (~€21,000) |
| Below ~890,000 zł | 10% of turnover | Less than 89,035.60 zł |
So Poland is not, in practice, a percentage-of-turnover regime like the one large providers face in Italy. Its ceiling is about €21,000 for a mid-sized shop and a national retailer alike.
What the law says
The penalty article is Art. 73. Its operative closing formula, which applies to manufacturers, service providers, importers and distributors alike, reads:
"w wysokości do dziesięciokrotności przeciętnego wynagrodzenia miesięcznego w gospodarce narodowej za rok poprzedzający, jednak nie większej niż 10% obrotu osiągniętego w roku obrotowym poprzedzającym rok nałożenia kary."
("...in an amount up to ten times the average monthly wage in the national economy for the preceding year, as announced by the President of the Central Statistical Office in the Official Journal of the Republic of Poland 'Monitor Polski' on the basis of the legislation on retirement and disability pensions from the Social Insurance Fund, but no greater than 10% of the turnover achieved in the financial year preceding the year in which the penalty is imposed...")
— Act of 26 April 2024, Art. 73(1) (ISAP), our translation
Art. 73 then adds the sentencing factors and the payment mechanics:
"The amount shall be determined having regard to the extent of the infringement, including its gravity, the number of non-compliant products or services, and the number of persons negatively affected."
— Art. 73(4)
"Penalties shall be paid within 14 days of the date on which the penalty decision became final, into the bank account of the Accessibility Fund."
— Art. 73(5)
That last detail is a small but telling one: Polish accessibility fines are earmarked. They don't go to general revenue — they go into the fund that finances accessibility work.
Doing this year's arithmetic
The statute points at a specific announcement: the average wage figure published by the President of GUS under the pensions legislation. That announcement was made on 9 February 2026, and it puts the average wage in the national economy for 2025 at 8,903.56 zł.
Ten times that is 89,035.60 zł — about €21,000 at roughly 4.25 zł to the euro.
For comparison, the same calculation a year earlier produced about €19,000, and the year before that about €17,000. Poland's ceiling has risen roughly 25% in two years without a word of the law changing, and it will move again next February. Any source quoting a fixed euro figure for Poland is quoting a snapshot, whether it says so or not.
The fine is not the risk. These two are.
If you take one thing from Poland, it should not be the €21,000.
1. A 180-day ban on providing the service. Where an inspection finds a service non-compliant, the authority can call for corrective action — and, separately, shut the service down while it waits:
"...may, by decision, prohibit the offering or provision of the service for a period not longer than 180 days."
— Art. 62(1)(2)
Art. 64 then allows that prohibition to be extended until the proceedings conclude. For products, Art. 52 does the same job. Six months off the Polish market is a category of harm that a €21,000 fine simply isn't in.
2. The complaint you didn't answer becomes an obligation. This is the provision almost nobody outside Poland knows about, and it's the one most likely to catch a foreign business. Any consumer can complain directly to the operator that a product or service isn't accessible (Art. 35). The operator has 30 days to respond, extendable to 60 only if it notifies the consumer inside the first 30. Then:
"Where the period under paragraph 2 or 3 is not observed, the complaint shall be deemed to have been resolved in accordance with the complainant's demand. The economic operator shall implement the complainant's demand within a period not longer than 6 months from receipt of the complaint."
— Art. 37(4)
Read that again. No regulator, no inspection, no finding that the complaint was even correct. A message sitting unread in a support inbox for 31 days converts into a binding obligation to do whatever it asked, within six months. And complaints can arrive by post, email, phone, or spoken in person to a written record (Art. 37(1)) — so "we only accept tickets through the web form" is not a defence.
Who enforces it
Poland spreads enforcement across seven sector regulators, with PFRON above them:
| Sector | Regulator |
|---|---|
| E-commerce | The ministry responsible for digitalisation |
| Retail banking | The Financial Ombudsman (Rzecznik Finansowy) — not the financial supervisor, which is unusual in the EU |
| Telecoms, audiovisual media, e-books, hardware and terminals | UKE |
| Bus and coach services | Voivodeship road transport inspectors |
| Rail | UTK |
| Air | ULC |
| Sea and inland waterways | The maritime offices / the Inland Waterway Office in Bydgoszcz |
Coordinating all of them is PFRON, the State Fund for Rehabilitation of Disabled Persons, which also inspects and fines in its own right and receives public notifications. Note the consequence of a sectoral split this fine-grained: an e-commerce business that also sells a credit product answers to two different regulators for the same website.
And under Art. 67, anyone — not only a customer — can notify PFRON that a product or service isn't accessible, including orally or in Polish Sign Language.
How enforcement unfolds
Poland won't fine you out of nowhere; the act builds in a long, documented runway:
- Inspection, triggered by reasonable doubt or a public notification.
- If your disproportionate-burden assessment is inadequate — at least 60 days to redo it.
- A call to take corrective action, with evidence required, within up to 120 days (Art. 62(1)(1)).
- Only if the evidence doesn't arrive does the authority open formal proceedings of its own motion (Art. 63).
- Decision — and only here can a penalty be imposed (Art. 73(3)).
Realistically that's around six months from first contact, if you engage. The 180-day prohibition, though, is available at step 3 — it doesn't wait for the end.
Has it been enforced yet?
No penalties have been published. PFRON's market-surveillance pages set out the structure and the regulators' remits but list no decisions, inspections or fines, and the supervisory bodies published their operating guidelines in mid-2025 rather than enforcement outcomes. Poland is at the same stage as most of the EU: the machinery is assembled and idle.
The exception, and it's a real one, is that the Art. 37 complaint route needs no regulator at all. It is live now, it runs on your own inbox, and nothing about it will ever appear in an enforcement statistic.
What this means for your business
The highest-return action in Poland costs almost nothing: put a named owner and a 30-day clock on accessibility complaints. Of the 27 national laws we checked, Art. 37(4) is the only provision that turns administrative sloppiness directly into a legal obligation, and it is entirely avoidable with a calendar reminder.
After that: work out which of the seven regulators covers you (and whether it's more than one); if you're relying on the disproportionate-burden defence, document the assessment properly and diarise a review every five years — and check whether you took any outside funding to make something accessible, because Art. 21(11) removes the defence for any requirement you were funded to meet. Then treat the €21,000 as what it is: the smallest of Poland's three consequences.
Frequently asked questions
What is the EAA fine in Poland?
There's no fixed amount. The ceiling is ten times the previous year's average monthly wage, capped at 10% of turnover. Using the figure published on 9 February 2026 (8,903.56 zł), that's 89,035.60 zł — about €21,000 for 2026.
Does the 10%-of-turnover cap mean big companies pay more?
No — it's the opposite. The fine can't exceed either limb, so for any business above roughly 890,000 zł of turnover the wage-based figure is the binding ceiling. The 10% only reduces the maximum for very small operators.
What's the worst thing that can happen in Poland?
Not the fine. A regulator can prohibit you from offering or providing the service for up to 180 days (Art. 62), and extend that until proceedings end (Art. 64).
What happens if I ignore a customer's accessibility complaint?
After 30 days (or 60 if you properly extended), it's deemed resolved in the customer's favour and you have six months to do what they asked — with no regulator involved and no test of whether the complaint was right (Art. 37(4)).
Who enforces the EAA in Poland?
Seven sector regulators, coordinated by PFRON — including the Financial Ombudsman for retail banking, which is not where most countries put it.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Official text: Act of 26 April 2024, Dz.U. 2024 poz. 731 (ISAP)
- Ireland's EAA fines — where the consequence is criminal rather than commercial
- How we verified all 27 national laws — our sourcing method
