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Blocking illegal sites
Poland has built a "double circuit" of the fight against unlicensed online gambling: domain blocking and payment restrictions. The goal is to protect players, contain the "gray" segment and ensure that the market operates strictly within the framework of licenses. Below is how the system works, who is responsible for what and what are the consequences.
1) Legal framework and areas of responsibility
Regulator: Ministry of Finance - forms policy, maintains domain registry, coordinates supervision.
KAS (tax and customs administration): field inspections, investigations, initiation of entering resources into the register.
Communication providers (ISPs): are required to restrict access to domains from the registry.
Payment organizations/banks/PSP: stop transfers in favor of domains/accounts associated with unlicensed sites.
Operators and affiliates: responsible for offering/advertising games without Polish license.
2) Countermeasures
2. 1 Domain lock register
Includes domains offering gambling without a Polish license.
After publication, ISP records must restrict access to the domain within the agreed period.
The blocking applies to the main domain and its subdomains, if necessary - to the "mirrors" added to the registry.
2. 2 Payment filters
Banks and PSPs stop accepting/sending payments for details associated with domains from the registry.
Includes card, bank and e-wallet transactions; it is possible to escalate to blocking individual merchant IDs.
2. 3 Additional measures
Removal of illegal advertising (including affiliates), requirements for hosting providers and site owners to remove illegal content.
Interaction with app stores when trying to distribute unlicensed brands to client APKs.
3) How a Domain Enters the Registry: Life Cycle
1. Detection: traffic monitoring, player complaints, KAS analytics, keyword and payment route crawlers.
2. Verification of signs: lack of a Polish license, presence of gambling functionality/acceptance of bets, Polish targeting.
3. Registry entry: domain publication with grounds.
4. Enforcement: ISPs block access, PSPs limit payments.
5. Appeal: the domain owner can file a motivated appeal; if legality is confirmed, the domain is excluded.
6. Mirror monitoring: repeated "overflows" - quick additions to the registry.
4) Player responsibilities and bypass consequences
The player is not criminally liable for the very fact of visiting the site, but risks loss of funds, lack of payments and protection of rights.
Attempts to "bypass" through VPN/mirrors lead to:- blocking/freezing of payments;
- impossibility to verify the winnings;
- lack of access to ombuds procedures;
- risks of personal/payment data compromise.
5) Sanctions for organizers and affiliates
Fines and suppression of activities, inclusion of domains/resources in the register.
Joint liability: the brand is responsible for advertising and branding partners.
Blocking payment flows and possible claims for damages/unjust enrichment.
6) Risks of "bypass" schemes and how supervision is responsible for them
Mirrors and frequent domain changes: operational registry replenishment.
Reselling payment channels: data exchange with banks/PSP, anomaly markers for MCC/merchant.
Disguise as information portals: analysis of actual functionality (deposits, coupon rates, feeds, KYC forms).
Pseudo-legal "gray" licenses: checking the targeting of Polish users and the fact of the presence of a Polish license.
7) Practice for players: quick checklist
1. Check the availability of the Polish license on the site (details, permit number).
2. Look for the sections "Rules," "Responsible play," "Privacy policy," operator's address in Poland.
3. See payment methods: working through "dubious" providers is an alarming sign.
4. Do not make a deposit if the site is opened only through a mirror/VPN.
5. Choose licensees: this is access to ombudsman proceedings, transparent payments and RG tools.
8) Practice for operators: how not to get into the register
Work only with a Polish license and on permitted verticals.
Store logs and calculations according to Polish standards, provide KYC/AML and RG "by default."
Configure geo-filters and block access for Polish users if there is no license.
Enter an affiliate code: pre-moderation of creatives, ban on "euphoric" tone, ban on target <18, SLA removal of violations ≤24 h.
Use white payment channels, avoid "gaskets" and resellers.
9) Transparency and proportionality
Blocking and payment restrictions apply pointwise to domains confirmed as unlicensed.
There is a procedure for appealing and adjusting the register.
The priority is the protection of players and the stability of the legal segment.
10) KPI of system efficiency
Share of traffic redirected from illegal domains to licensees.
Reduce payments for blocked resources.
Time from detection to blocking and average duration of appeals.
Number of illegal creatives filmed at affiliates and reaction time.
11) Short answers to frequent questions (FAQs)
If the site has changed its domain, is it legal? No, it isn't. Legality is determined by license, not domain name.
Why didn't my payment go through? Probably domain/recipient in the registry - transactions are blocked.
Can I withdraw money from an unlicensed site? There are no guarantees; legal protection - too.
The Polish model "domain registry + payment filters" makes bypassing unlicensed sites economically meaningless: without traffic and payments, the "gray" segment loses ground. For the player, the best choice is licensees: protected payments, ombuds mechanisms and responsible play tools. For operators, the only long-term way is to work in the legal field, comply with KYC/AML/RG and tightly control affiliates.