Is Poland an undervalued market?
Despite structural frictions and political deadlock, Poland is positioning itself as one of the most compelling long-term plays for international operators. Marek Plota, gambling lawyer and Founder, RM Legal and Gaming in Poland, writes for Global Gaming Insider.
Poland is a market too big to ignore. Those who delay risk ceding the field to faster movers.
With 38 million consumers, Poland is the largest gambling market in Central and Eastern Europe and one of the fastest-growing regulated sports-betting jurisdictions in the EU. The market’s momentum is particularly visible in the 2024 figures, with sports betting turnover reaching €3.49bn ($4.04bn) and GGR amounting to €567m, reflecting a robust 25% year-on-year growth rate. Online betting channelisation remains high at approximately 75-80%, signalling effective migration of players into the regulated offer. At the same time, the cost of securing a licence is comparatively low by European standards, reaching only €175,000 for a six-year period, with no additional annual maintenance fees.
Even more striking is the competitive story. Between 2019 and 2024, two foreign operators, Betclic and Superbet, entered the market from zero and built 20–25% market share each, rapidly reshaping an industry historically dominated by STS (now owned by Entain) and Fortuna. In a market where operators often overestimate barriers to entry while underestimating its scale, this kind of ascent is exceptionally rare in Europe; and it demonstrates that strong product, brand discipline and local understanding still translate into meaningful, defensible market share.
Regulation under pressure
Poland’s regulatory framework is a hybrid unlike any other in Europe. The 12% turnover tax burdening bookmakers continues to distort pricing, while the state monopoly on online casino leaves a large part of consumer demand unserved by the regulated offering. As a result, around 1.2 million Poles still use offshore platforms. Yet for the first time since 2016, the political atmosphere around gambling is no longer one of avoidance or defensiveness, but of cautious institutional engagement. This change is structural, not cosmetic.
Over the past 18 months, the Ministry of Finance established the Department for Gambling Market Regulation and Gambling Tax, creating the first truly specialised regulatory arm in the sector’s recent history. In parallel, the Inter-Ministerial Team on Countering the Grey Market has begun coordinating enforcement, data exchange and technological tools aimed at cutting off the economic infrastructure of unlicensed operators.
For the first time in over a decade, public institutions are not treating gambling as a problem to be contained, but as a market to be managed. That shift alone opens the door to reforms that were previously politically unthinkable.
Discussions on replacing turnover tax with a GGR model and on the future of the monopoly are now taking place across parliamentary committees, ministerial briefings and stakeholder roundtables. While the adversarial post-election dynamic between the President and Prime Minister will likely slow any legislative vote until 2027, the reform infrastructure is being quietly built today.
A window of opportunity
Many international operators hesitate to enter Poland, preferring to wait for clearer rules. Yet this “wait-and-see” instinct is one of the biggest strategic miscalculations in the region. Enforcement tightening is already pushing players from unlicensed to licensed channels. Payment blocking, most importantly restrictions on BLIK, the country’s dominant payment method, has materially weakened the offshore ecosystem. Domain-blocking tools are improving, and cooperation with fintechs and Big Tech is increasingly standardised. Each enforcement step strengthens the value of holding a licence and accelerates channelisation.
Equally important is the political reality. Operators who are not present in Poland have no influence on shaping the upcoming regulatory framework. Those who expect others to fight their regulatory battles will find themselves at the back of the queue when the Polish market inevitably modernises. Policy development in Poland tends to favour stakeholders who demonstrate commitment, invest early and build credibility with regulators, rather than those waiting abroad for someone else to shape the environment.
The Polish market also consistently rewards early operators who execute decisively. The meteoric rise of Betclic and Superbet clearly shows that the market continues to value product quality and consumer engagement above incumbency. Those already positioned in the market when reforms arrive, whether on tax, casino liberalisation or enforcement, will have a structural advantage in capturing the next growth wave.
Route to market: Licensing via a representative
One of Poland’s least understood strengths is its simplicity and low cost of entry. Foreign operators are not required to set up a Polish company, and there are no restrictions on non-EU board members or shareholders. They may operate using existing EU infrastructure, such as Maltese or other EU hubs, while their local responsibilities are handled by an Appointed Representative. This representative acts as a formal interface with public authorities, including the Ministry of Finance, tax office, customs, police and prosecutors. They prepare all tax filings, statutory reports and handle audits on behalf of the operator.
This model keeps overheads lean, enables staged market entry and allows operators to secure a licence now while launching commercially at the ideal moment. Poland is one of the few major European markets where you can secure a licence, wait strategically, and enter on your own terms. This flexibility, combined with market scale, is a unique offering.
The keystone of CEE Strategy
Poland is the economic anchor of Central and Eastern Europe and the region’s largest digital consumer market. Any operator aiming to build a credible CEE footprint cannot bypass Poland without leaving a structural gap in its strategy. With €3.5bn in turnover, strong year-on-year growth and increasingly sophisticated enforcement, Poland is evolving into a primary regional hub for sports betting, despite unresolved tax and monopoly issues. With consolidation accelerating and early movers shaping the policy debate, the opportunity is already materialising.
A market on the edge of transformation
Poland is a market in transition. It is complex, imperfect and politically polarised. Yet it is also one of Europe’s last remaining large-scale opportunities where early regulatory engagement still delivers a disproportionate competitive advantage. Population size, robust channelisation growth, proven scalability of new entrants and low-cost licensing, make the country too valuable to overlook. Operators who move now will shape the next regulatory chapter. Those who wait will find that by the time reforms arrive, the most strategic positions in the market have already been claimed.
Marek Plota is a gambling lawyer and founder of RM Legal and Gaming in Poland. He advises international operators on Polish and EU gambling regulation, with a focus on end-to-end support at both the licensing and post-licensing stages, including regulatory, tax, technology and compliance work. He also acts as an authorised gambling representative for foreign operators before Polish public authorities, providing a local interface for regulatory and tax matters. Marek has participated in industry consultations with lawmakers, the Ministry of Finance, regulators, and the financial sector aimed at improving Poland’s gambling framework and countering the grey market. He is a member of the International Masters of Gaming Law (IMGL).