Poland - Ministry of Finance: offline/online limits

(Section: "Markets and Jurisdictions")

1) Supervision frame and article object

The coordination of the gambling market in Poland is carried out by the Ministry of Finance (MF). Executive control and checks are carried out by KAS (Krajowa Administracja Skarbowa - Tax and Customs Administration). The material focuses on limits: what restrictions apply to offline formats (casinos, machine shops, betting shops) and how online limits are arranged (deposits, losses, session duration, identification, promo and RG).

2) Key players and control tools

MF - market rules, licensing/concessions by type of game, responsible play policy.
KAS - checks, investigations, fines, blocking of illegal domains and payments.
Registers and lists - centralized bases for blocking sites/payments; registers of exceptions/restrictions on access to halls and online games.
Payment providers/banks - compliance with MF/KAS requirements for locks and verification.

3) Offline limits: what is important to the operator

3. 1 Quotas and geography

License quotas and address binding: the number of casinos and slot machine salons is limited by regulations and tied to settlements/voivodeships.
Zoning and distances: local rules for distance from schools/social facilities, requirements for signs and entrance group.

3. 2 Access and age

Age threshold: admission only to adults (strict check of the document at the entrance).
Denial of service: mandatory refusal to persons from the registers of exceptions/self-exclusions and in cases of signs of problem play.

3. 3 Product and process limits

Bet/potential winnings/game speed: for machines and tables, the established limit parameters (bets, rotation frequency, winnings) apply.
Opening hours: the scope of the operating hours of the halls and teaching staff may be limited by municipal acts.
Cash transactions: cash discipline, cash limits and mandatory reports on large transactions.

3. 4 UX and transparency

RG marking: mandatory warnings, visible chances/rules, info stands.
Video Surveillance/CCTV: Records stored on time for subsequent inspections.

4) Online limits: RG matrix and anti-abuse

4. 1 Identification and access

Full KYC before admission to play/payouts: identity, age, address; sanctions/RAP; confirmation of payment means.
Two-factor login security and multi-account/device sharing monitoring.

4. 2 Player Financial Limits

Deposit limits: daily/weekly/monthly, set by the player and/or preset by default.
Loss limits: Limit net losses for a period with automatic blocking when a threshold is reached.
Betting/winning limits: size limits for individual products/markets.
Pauses and "cooling": instant timeouts (from minutes/hours) and long periods of self-exclusion.

4. 3 Time and behavioral constraints

Session duration limit: warnings about the time in the game, auto-logout after the threshold.
Night restrictions/triggers: additional checks and flags for games at night.
Behavioral scoring: pursuit of losses, quick re-deposits, jumps in bets - initiate warnings/escalation to the RG team.

4. 4 Bonuses and promos

Clear T&C and wagers: transparent wagering goals, deadlines, caps of winnings from the bonus.
Prohibition of aggressive advertising and targeting of minors/self-excluded.
Responsible promotional circuit: pre-moderation of creatives, log storage of screenshots/URL/dates.

5) Registers and block lists

5. 1 Exception registries (offline and online)

Exception to the application: a citizen can restrict his access to ground halls and/or an online channel for a set period.
Verification duty: the operator is obliged to check the user with the register at registration, entry and key transactions (deposits/payments).
Marketing blocking: mailings and offers to self-excluded are prohibited.

5. 2 Register of illegal domains/payments

Domain Block List: Carriers are required to restrict access to MF/KAS sites.
Payment locks: payment providers do not conduct transactions in favor of illegal schemes.

6) Accounting, reporting and fiscal contour (by limits)

Separate accounting offline/online and by types of products; separate bonus registers, void/cashout.
E-reporting: forms and uploads according to the established formats; payment deadlines are strictly fixed.
Traceability of limits: store logs of all changes to the player's limits (who/when/where), attempts to exceed and system locks.
RG evidence base: logs of warnings, timeouts, self-exclusions, communications with the client.

7) Technical requirements

RNG/platform/simulation modules - certified by recognized laboratories; periodic recertification.
WORM logging: immutable logs of rates/payments/adjustments, time synchronization, time zone control.
Regulator access: API/uploads, test accounts, secure channels.
DR/BCP: target RPO/RTO, regular exercises, data redundancy.
Security: encryption at rest/in transit, RBAC/SoD, pentests and scans of vulnerabilities on a schedule.

8) Operator playbook

1. Strategy: product matrix (casino/betting/lotteries), channels (offline/online), partners.
2. Legal form and key persons: founders/beneficiaries, local AML/RG officers.
3. Licensing/concessions: package of documents, financial model, internal policies.
4. IT and RG contour: implement limits (deposit/loss/session), integration with registries, bonus engine with transparent accounting.
5. Finkontur: separate offline/online accounting, reporting forms, deadline control.
6. Marketing: white list of creatives, exception filters, quick recall process.
7. UAT: test cases for exceeding limits, self-exclusion, timeouts, behavioral alerts.
8. Go-Live: freeze configurations, incident plan, contact window with KAS/MF.
9. First 90 days: otchetnost↔billing reconciliations, RG/AML audits, limit adjustments.

9) Compliance checklists

Limits and RG

• Included and tested: deposit/loss/session/timeout/self-exclusion
• Limit changes and overshoot attempts are logged
• Integration with exception registers and checking in/out
• Blocking Promo for Self-Excluded

Offline

• Compliance with quotas, address permissions and hours of operation
• Age control at input, failure logs
• CCTV/record storage, cash discipline
• RG Info Stands, Labeling, and Escalation Procedures

Online/IT

• RNG/Platform Certification, Version Control
• Immutable logs, time synchronization, redundancy
• Regulator access (API/uploads), test accounts
• Pentests/Scans, RBAC/SoD, Secret Management

Marketing/Affiliates

• Approved creatives and compliance log (screenshots/URLs/dates)
• Filters excluded in CRM/CDP, rejection of "aggressive" offers
• Transparent bonus T & Cs, correct accounting in NGR/GGR

10) KPI and operational control

RG: proportion of players with active limits; blocking time when exceeded (<1 min); proportion of repeated limit violations.
AML/KYC: average verification time, false positives fraction, escalation SLA.
Fiscal: timeliness of declarations ≥99%, discrepancy otchetnost↔billing <0.5%.
Information base: MTTR on incidents, pentest coverage, closure of critical vulnerabilities on time.
Marketing: 100% filtering of self-excluded, speed of recall of creatives, share of compliant traffic.

11) FAQ

Is it possible to change the deposit limit immediately?
Increase - only with delayed entry (cooling period); decrease - immediately.

Do I need to check the registry every time I sign in?
Yes I did. Verification is required for registration, login and before key transactions.

Are bonuses limited?
Yes, there are T&C transparency requirements, banning "dark patterns" and promos for excluded individuals.

Are there fixed quotas for offline locations?
Yes, the number of addresses is limited by regulations and the population of the territories; locations are approved address.

Note

Specific numerical thresholds (bets/game speed/quotas/self-exclusion deadlines), reporting formats and integration requirements are periodically updated in MF acts and KAS regulations. Before starting, check the current forms, field dictionaries and technical specifications to avoid additional charges and stops.