Legal Gaps in Oversight

The main challenge is the absence of a permanent legal basis for the national digital services coordinator. Currently, this role is temporarily held by the President of the Office of Electronic Communications (UKE), who does not have a permanent legal mandate. The Office of Competition and Consumer Protection is listed as the second supervisory institution under the oversight model.

According to EU regulations: “Member States were required to appoint national DSA regulators by February 2024. Poland missed this deadline, and the case may be referred to the Court of Justice of the European Union.”

The European Commission has launched infringement proceedings against Poland, holding the Ministry of Digitalisation and the Council of Ministers responsible for implementation.

Risks for Internet Users and the Market

Delays in DSA implementation have tangible consequences for Polish internet users. The regulatory gap increases the risk of disinformation, illegal advertising, and other harmful digital practices.

“Polish users currently lack effective mechanisms to seek redress against illegal content, scams, and material affecting child safety,” analysts warn.

Uneven enforcement of the DSA across EU countries weakens the Union’s ability to uniformly regulate tech giants and protect citizens’ digital rights.

Poland Defends Its Pace

The government argues that the slow rollout reflects the need to develop careful and high-quality regulations. “Extensive rounds of consultations demonstrate a responsible approach to the issue,” officials say. Despite this, no regulatory decisions have been made since early 2025.

Experts stress that effective enforcement of the DSA requires a clearly defined national coordinator with proper authority and a coherent oversight system. Continued delays are likely to lead to referral to the CJEU and financial penalties for Poland.

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