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Artificial Intelligence and Consumer Rights: Legal Responsibility for Algorithmic Decisions in the Polish and Eu Regulatory Context Cover

Artificial Intelligence and Consumer Rights: Legal Responsibility for Algorithmic Decisions in the Polish and Eu Regulatory Context

Open Access
|Dec 2025

Figures & Tables

Examples of AI applications in the consumer market and their associated potential benefits and risks_

Example of AI application in the consumer marketBenefitsRisks
Personalization of offers and advertisingAnalyzing data on potential consumer preferences and behaviors (e.g. their purchase history or records of previously viewed products) to recommend goods or services best suited to individual needs.Concerns regarding consumer privacy (with respect to completed or planned purchases) and the unauthorized use of personal data. One corporate study found that in Poland, “61% of individuals using digital services such as online store applications fear that the information they provide may contribute to identity theft” (EY, 2024)
Customer service chatbotsEnabling consumers to access support or obtain responses to their inquiries at any time, eliminating the need to wait for a human agent to become available.Consumers are not always able to obtain accurate information from chatbots – Poland’s Office of Competition and Consumer Protection (UOKiK), for instance, has received complaints regarding the improper functioning of such systems.
Dynamic pricing and personalized price offersIncreasing market efficiency and the ability to adjust prices to market conditions.Consumers may pay more for a product or service because the algorithm overestimates the consumer’s ability to pay. Online price differentiation may be perceived as unfair, especially if other customers can pay less for the same product.
Automated financial decision-makingAccelerating decision-making in finance, such as creditworthiness assessment, loan approval, or insurance issuance.Algorithms may rely on biased data that discriminates against certain consumer groups, often lacking transparency in the decision-making process – for example, in cases of allegedly unjustified denial of credit or loans.
Analysis of online opinions and reviewsEnabling entities that use AI-supported monitoring of online opinions and reviews of their services or products to respond quickly to any negative feedback.AI bots may be used to automatically delete negative comments or generate fake positive reviews, thereby misleading consumers.

Comparison of the scope of responsibilities of Polish institutions overseeing the consumer market_

Compared featurePolish Office of Competition and Consumer Protection (UOKiK)Polish Personal Data Protection Office (UODO)
National legal act regulating the scope of an entity’s responsibilityPolish Act of 16 February 2007 on Competition and Consumer ProtectionPolish Act of 10 May 2018 on the Protection of Personal Data
Scope of responsibility of the president of the institutionThe President of the Office of Competition and Consumer Protection (UOKiK) is the central government administration authority competent in matters of competition and consumer protection (Article 29 (1)).The responsibilities of the President of the Office of Competition and Consumer Protection (UOKiK) include, among others:
  • monitoring entrepreneurs’ compliance with the provisions of the Act on Competition and Consumer Protection;

  • issuing decisions in cases concerning anti-competitive practices, concentrations of undertakings, the recognition of unfair terms in standard contracts, practices that violate the collective interests of consumers, as well as other decisions provided for under the Act on Competition and Consumer Protection;

  • cooperating with national and international authorities and organizations responsible for the protection of competition and consumers (Article 31).

The President of the Office of Competition and Consumer Protection (UOKiK) may impose a financial penalty on an entrepreneur who, whether intentionally or unintentionally, has committed, among other things, a violation of the prohibitions set out in the Act on Competition and Consumer Protection (Article 106 (1)).
The President of the Personal Data Protection Office (UODO) is the competent authority for personal data protection and the supervisory authority within the meaning of the GDPR (Article 34 (1) and (2)).The President of the Personal Data Protection Office (UODO) carries out inspections to ensure compliance with personal data protection regulations (Article 78).The President of the Personal Data Protection Office (UODO) may impose a financial penalty on an entity obliged to comply with the provisions of the GDPR (Article 101).
Scope of responsibility of entities supporting the president of the institutionThe President of the Office of Competition and Consumer Protection (UOKiK) performs duties with the assistance of the Office of Competition and Consumer Protection (Article 29 (6)). The Office consists of the Central Office in Warsaw, regional branches, and laboratories supervised by the President of the Office (Article 33).The statute of the Office, which defines its organizational structure, responsibilities, and the location of its regional branches, is issued by the Prime Minister (Article 34).The current mission of the UOKiK is “to enhance consumer welfare by effectively protecting their interests and safety, and by supporting the development of competition (…)” (UOKIK, n.d.).The President of the Personal Data Protection Office (UODO) performs their duties with the assistance of the Personal Data Protection Office (Article 45 (1)).The President of the Personal Data Protection Office (UODO) grants the Office its statute, specifying, among other things, the scope of tasks and the working procedures of the Office’s organizational units (Article 45 (3)).Among its responsibilities, UODO examines how the development and use of Artificial Intelligence affect personal privacy and data protection.The President of UODO is also supported by an advisory and consultative body – the Council for Personal Data Protection – established under Article 48 (1), whose administrative services are ensured by the Personal Data Protection Office in accordance with Article 48 (15).The tasks of the Council include, among others:
  • issuing opinions on draft documents of EU bodies and institutions concerning personal data protection;

  • issuing opinions on draft legal acts and other documents concerning personal data protection submitted by the President of UODO;

  • developing proposals for recommendations regarding technical and organizational measures applied to ensure the security of personal data processing;

  • initiating activities in the field of data protection and presenting the President of UODO with proposals for legislative changes in this area (Article 48 (2)).

Selected examples of legal acts protecting consumers from the negative consequences of algorithmic decision-making_

Legal actExamples of legal acts protecting consumers from the negative consequences of algorithmic decision-making
Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)Article 22(1) “The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.” – This provision establishes the consumer’s right to object to decisions based solely on the automated processing of their personal data.
Directive (EU) 2019/2161 of the European Parliament and of the Council (Omnibus)(45) “Consumers should (…) be clearly informed when the price presented to them is personalized on the basis of automated decision-making, so that they can take into account the potential risks in their purchase decision. Consequently, a specific information requirement should be added to Directive 2011/83/EU to inform the consumer when the price is personalized, on the basis of automated decision-making.” – In other words, before making a purchase, the consumer must be informed if the price has been algorithmically personalized.(47) “(…) when traders provide access to consumer reviews of products, they should inform consumers whether processes and procedures are in place to ensure that the published reviews originate from consumers who have actually used or purchased the products.” – This provision aims to counteract the publication of reviews that are automatically generated by AI or do not reflect genuine consumer experience.
Polish Act of 23 August 2007 on Counteracting Unfair Market PracticesArt. 6 (4) and (7) “In the case of an invitation to purchase a product, the following shall be regarded as material information (…) in particular: (…) information on whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product – in the case of a trader who provides access to consumer reviews of products.” – Preventing the publication of AI-generated reviews.
Polish Act of 30 May 2014 on Consumer RightsArticle 12 (1) “No later than the time the consumer expresses their intention to be bound by a distance or off-premises contract, the trader shall be obliged to clearly and comprehensibly inform the consumer of: (…) the total price or remuneration for the service, including taxes, (…) any individualized pricing based on automated decision-making, where such pricing is applied by the trader; (…) the existence and content of any guarantees and after-sales services, and the manner in which they can be exercised.” – The consumer has the right to receive all necessary information regarding the contract concluded with the trader, regardless of whether it is concluded in person or, for example, remotely with the support of a chatbot – including information on any individualized pricing based on automated decision-making.
Polish Civil CodeArticle 449 (1) “Anyone who, in the course of their business activity, manufactures a defective product (the producer) is liable for damage caused to anyone by that product.” – A consumer may invoke this provision in cases where damage is caused by a system operated using AI tools – for example, a fire resulting from incorrect decisions made by Artificial Intelligence in the operation of “smart” electronic devices.
DOI: https://doi.org/10.2478/minib-2025-0006 | Journal eISSN: 2353-8414 | Journal ISSN: 2353-8503
Language: English
Page range: 1 - 24
Submitted on: Aug 10, 2025
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Accepted on: Oct 14, 2025
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Published on: Dec 29, 2025
In partnership with: Paradigm Publishing Services
Publication frequency: 4 issues per year

© 2025 Anna Maria Wierzchowska-Dziawgo, published by ŁUKASIEWICZ RESEARCH NETWORK – INSTITUTE OF AVIATION
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 License.