Poland Requires Apple to Modify Tracking Messages Within Two Months

The Polish Office of Competition and Consumer Protection (UOKiK) announced on October 20 a commitment decision No. DOK-7/2026 regarding Apple, Apple Distribution International, and Apple Operations International, following an investigation into the App Tracking Transparency policy in iOS and iPadOS. The office concluded that Apple may hold a dominant position, and that the ATT policy defined "tracking" as combining user data from applications of different companies to display personalized ads, requiring an additional message to be shown, whereas Apple's own data collection or display of personalized ads was not considered "tracking," so it was not obliged to request additional consent.

Under the decision, consent messages in Apple's apps and other developers' apps will become neutral in appearance, order, and content, and marks, images, and wording that might influence user choice, including the word "tracking," will be removed. Apple will also provide accurate information about how data is used, with a link to a page or additional display explaining the processing in more detail, without interfering with its content.

Apple will be required to inform publishers of its commitments and changes in the ATT policy, and publish this in the terms and guidelines directed at them. The office also created the position of an independent liaison officer to receive developer feedback, questions, and complaints in Polish or English, and refer them to an independent monitoring trustee who reviews publisher complaints regarding the ATT policy. Apple must implement the commitments within two months of the decision becoming final, and submit documents proving implementation, along with annual reports.

UOKiK President Tomasz Chróstny said that fair competition rules apply to everyone, including the largest tech companies, and that the office does not hesitate to intervene when restricting competition is suspected, noting ongoing investigations with Google and Meta. This decision was preceded by similar decisions in France in March 2025 and Italy in December 2025, and a German commitment decision in August 2026, coming as a culmination of months-long cooperation with the European Commission.

What do these terms mean?

App Tracking Transparency: A policy by Apple that sets the conditions for app developers to obtain user data and request permission before tracking.

Dominant Position: A position of market power that enables a company to influence the market on its own, and its abuse is prohibited by law.

Commitment Decision: A regulatory decision in which the investigator accepts a company's pledges to change its practices instead of imposing a fine.

Monitoring Trustee: An independent entity that follows up on the implementation of the company's commitments and considers complaints from affected parties.