UODO fine for ignoring an official request: PLN 10,082
In brief
- UODO fined the RKW association PLN 10,082 for failing to answer the authority's requests and hand over documents. The announcement is dated October 26, 2026.
- Two letters came back to the authority unclaimed, and under the Code of Administrative Procedure they counted as delivered anyway.
- The fine is no longer collected by UODO but by the head of the tax office, and enforcement adds 10% of the amount on top.
- Od 1 października 2026 roku firma wpisana do CEIDG ma mieć aktywny adres do e-Doręczeń. To tam przyjdzie następne pismo z urzędu.
- The fine is for the silence itself. The case of how the data was processed in the app is still pending.
On October 26, 2026, UODO announced that it had fined the RKW association PLN 10,082 for failing to cooperate with the authority. A UODO fine for ignoring an official request does not settle whether anyone processed data lawfully: you pay here only because the authority asked and nobody wrote back. Collecting the amount has been taken over by the tax office.
UODO fine for ignoring an official request: how the case unfolded
The authority asked about things that would take an hour to answer: what categories of data the web form collected, whether IP addresses and device data went with them, and where that data physically sat. The first request went out in June 2025, the second in July. Both letters came back unclaimed, and with substitute delivery a letter sits at the post office for 14 days, after which it is deemed delivered (Article 44 of the Code of Administrative Procedure). Every letter included a warning about the fine.
In October 2025 a UODO employee called. They were told the letters had never arrived and sent them again. This time the mail was collected, and an answer still never came back to the authority. That is what follows from the UODO announcement about the fine for failing to provide information.
Who this affects in Poland
A request from UODO is not reserved for companies that process data on a large scale. A repair shop with a contact form will get one, and so will a clinic with patient files or an accounting office that a client sent a scan of their ID to. The reason is often trivial: one complaint, one question about who controls the addresses from a newsletter.
The association is not a business, so the amount came out low. For a company the ceiling is different: failure to cooperate with the supervisory authority sits in Article 83(5) of the GDPR on the same shelf as serious infringements, which means up to 20 million euros or 4% of annual turnover. If you are not sure what your website promises in its forms and privacy policy, start with a free website audit, because those are the documents the official reads.
PLN 10,082 fine for failing to provide information
14 days how long a letter sits before it is deemed delivered
10% enforcement fee on the amount collected
Note
From October 1, 2026, a business registered in CEIDG before 2025 is required to have an active adres do e-Doręczeń. Filing the application alone does not close the matter, the mailbox has to be switched on. If you set it up because you were told to and never went back there, today that is the place where your first letter from a public authority is waiting.
What this means for your business
W małej firmie adres w rejestrze bywa adresem mieszkania sprzed dwóch przeprowadzek, a do skrzynki e-Doręczeń loguje się księgowa raz na kwartał. Urząd nie musi Cię wtedy znaleźć, żeby skutecznie doręczyć pismo, a po terminie rośnie rachunek: egzekucja dolicza 10% ściągniętej kwoty, przy zapłacie po jej wszczęciu 5%.
Source: Article 64 of the Act on Enforcement Proceedings in Administration, 17.06.1966
What to do this week
- Read your address in the register. Open your own entry in CEIDG or KRS and check the address for service. The letter will go there, not to where you actually sit.
- Zaloguj się do e-Doręczeń. Check whether the mailbox is active and whether anything is sitting in it. Appoint an administrator if someone other than you is to handle it.
- Name one person for official mail. In a three-person company "everyone checks" means "nobody checks". Write down who opens letters and what they do when something from UODO arrives.
- Answer by the deadline, even partially. If you cannot gather the documents in time, write what is missing and ask for more time. The request stays in the file, and so does silence, it just costs money.
What we still do not know
Neither the authority's announcement nor the Prawo.pl report gives the date or reference number of the decision, so you cannot check whether it is final and whether the association took it to the administrative court. It is also unknown how the authority calculated the amount. The heart of the case, the lawfulness of verifying voters in the app, will be decided in separate proceedings.
If you want someone to take an outside look at your forms and privacy policy, call 511 608 362 Monday to Friday between 10 a.m. and 6 p.m. This post is information about a case, not legal advice.
Frequently asked questions
How long do I have to answer a request from UODO?
The letter itself states the deadline, usually 7 or 14 days from delivery. What counts is the delivery date, not the day you looked in your mailbox.
Can I say I never got the letter?
You can, but it rarely helps. Here the association reported that it had not seen the letters, the authority sent them again, and the fine came anyway, because no answer arrived.
What should I do if my clients' data leaks?
A report to UODO has its own deadline and its own form. We described it using the example of the Fakturownia data breach: what to report, when, and what to tell your clients.
Where do I find similar obligations in an online store?
They sit in the documents you need to have anyway: what an online store's terms and conditions must include and when you may change the terms during a contract.
