DSA implementation in Poland – timeline

Article
19.12.2025
6 min. read
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Zdjęcie przedstawiające książkę z okładką: Europe Digital Services Act

It’s been whole three years since Digital Services Act was adopted. But even though it became fully effective in February 2024, Poland has not yet implemented it. This means that our people cannot benefit from the protection it offers against internet platforms’ harmful practices. Whereas for Panoptykon it means that instead of advocating for DSA rules to be executed, we analyse new and new versions of the implementing act, demand for measures protecting freedom of speech against the “state censorship”, and crusade to the parliamentary hearings time and again. Don’t believe it? Check out the timeline of DSA implementation in Poland.

19.10.2022The European Union adopts the DSA. Member states should implement the new rules on national level by February 17, 2024.
17.10.2022The Chancellery of the Prime Minister meets with representatives of business and civil society. Under pressure from i.a. Panoptykon the politicians promise to publish the implementation concept “soon”.
October 2023Deadline for national implementation is around the corner but nothing is happening. We know the Ministry of Digital Affairs works on the draft implementation but it is not officially announced before the end of the government term. Politicians focus on the parliamentary elections.
11.05.2023We find an error in the Polish translation of the DSA. One of the obligations imposed on platforms in the Polish translation of the Article 27 seems to be limited to VLOPs only, while in fact all the platforms have to comply to it.
29.06.2023A corrigendum to the Polish translation of Article 27 of the DSA is published in the EU’s Official Journal.
5.01.2024The Ministry of Digital Affairs publishes the concept of the DSA implementation.
19.01.2024Panoptykon submits its opinion (#1) to the concept of the implementation.
17.02.2024Time to implement DSA on the national level is up.
15.03.2024The Ministry of Digital Affairs publishes the draft law implementing the DSA.
12.04.2024Panoptykon submits its opinion (#2) to the draft law implementing the DSA. We emphasise the need to financially support the operations of the out-of-court dispute settlement bodies, to provide sufficient budget for the Digital Service Coordinator – the new guardian of our digital rights, and to create an advisory body to the DSC. The body should include representatives of the civil society. We also advocate for independent oversight of platforms removal decisions.
24.04.2024The European Commission urges Poland to implement DSA. The government should i.a. appoint the national Digital Services Coordinator.
19.07.2024The Ministry of Digital Affairs publishes a new version of draft law implementing the DSA. Our recommendations regarding the out-of-court dispute settlement bodies are introduced. The DSC’s budget is increased and an advisory body is to be created. There is also a new quick judicial track to settle content moderation disputes. Only a narrow scope of cases will be directed to the administration bodies – the Office of Electronic Communications and the Office of Competition and Consumer Protection – rather than directly to court.
14.08.2024Panoptykon submits its opinion (#3) to the draft law dated July 2024. Though the quick court dispute settlement track does not stem from the DSA, we find it quite appealing – after all independent mechanisms of verifying platforms’ arbitrary decision to block content are quite needed. We however criticise the idea of leaving some of the cases to be settled by the administration bodies rather than the court.
24.09.2024Another version of the draft law is published. But instead of directing all cases to the court (great idea!), the Ministry wants all the cases to be reviewed by the Office of Electronic Communications. A very risky concept unless followed with strong control measures.
16.12.2024The European Commission urges Poland to implement the DSA. Again.
January 2025The Ministry publishes yet another version of draft law. Only minor changes compared the September one are made. Controversial measures are left intact. The draft law attracts media attention and creates “censorship” havoc. Panoptykon joins forces with the Helsinki Foundation for Human Rights to publish a critical opinion (#4), emphasising on the risk of freedom of speech being limited unless proper control measures are introduced.
7.04.2025The Chancellery of the Prime Minister organises a public hearing concerning the proposed amendments to the act on electronic services. If there was a headline, it would read: is the President of the Office of Electronic Communications going to censor the internet?
7.05.2025The European Commission takes Poland (as well as the Czech Republic, Spain, Cyprus, and Portugal) to the EU Court of Justice for failing to implement the DSA on the national level.
13.05.2025The government appoints the President of the Office of Electronic Communications as a “temporary” DSC for Poland. That’s all for now – politicians keep themselves busy with the upcoming presidential elections.
19.07.2025Another version of draft law is published. The Ministry of Digital Affairs seems to have heard critical voices of Panoptykon and other organisations and narrows the scope of cases to be settled by the President of the Office of Electronic Communications. The President’s decisions will be subject to court control. Also, the author of the disputed content will have a say in their case: they are to be allowed to advocate for themselves in the whole procedure. The draft law still lacks a provision that would allow most users harmed by unfair content removal decisions to refer their case to the President of the Office of Electronic Communications, with the prospect of obtaining a decision to restore the content.
18.09.2025A couple of new positions are added to the list of illegal content to be subject to the President of the Office of Electronic Communications’ decisions. No other major changes are made to the draft law, which is now referred to the Cabinet.
23.09.2025The Cabinet approves the draft law implementing the DSA and passes it on to the Parliament.
24.09.2025A hearing for the candidate to become the new President of the Office of Electronic Communication is being held in the Sejm, the lower chamber of Parliament. During the session, Przemysław Kuna addresses questions and concerns about the future competencies of the office, as outlined in the implementation of the Digital Services Act, including the proposed procedure for blocking online content.
17.10.2025The Sejm Commission for Digital Affairs and New Technologies organises a public hearing on proposed amendments to the act on electronic services. We brace ourselves for yet another battle over censorship, while still hoping to persuade policymakers that the implementation of the DSA in Poland is truly necessary.
November 2025The Sejm approves the act on electronic services and passes it on to the Senate. An important amendment is added in the process, in favour of users’ whose content was unduly blocked by internet platforms. The President jumped the gun by suggesting a veto, even before the law left the parliament.

What is going to change in the draft law during the parliamentary proceedings? Will Senate pass the law? What will the President do? It will be definitely continued.

Topic
law