New Sanctions Act passed by the Sejm. What does it mean for businesses?

On 6 November 2026, the Sejm passed the Act on Restrictive Measures (UC92), which is intended to significantly change Poland’s system for applying and enforcing economic sanctions. MPs approved two amendments and rejected the remaining proposed changes. The new legislation provides for administrative fines of up to PLN 20 million, criminal liability, and financial penalties for collective entities of up to PLN 200 million or 5% of revenue. Most of the Act’s provisions are expected to enter into force just 30 days after publication.

Work on the new sanctions legislation, which we reported on previously, has reached another significant milestone. On 6 November 2026, during its 68th sitting, the Sejm passed the Act on Restrictive Measures (parliamentary paper no. 3003).

A total of 240 MPs voted in favour of the Act, 202 voted against it, and one abstained.

The Act is intended to consolidate the previously fragmented rules on the application of EU and national sanctions, define the powers of the responsible authorities, and introduce a comprehensive system of liability for violating and circumventing restrictive measures.

For businesses, this means the prospect of significantly greater legal risk associated with international trade, transactions with foreign counterparties, and international supply chains.

Which Amendments Did the Sejm Adopt?

Several amendments were proposed during the legislative process. On 6 November 2026, the Sejm adopted two of the amendments presented in the supplementary committee report (parliamentary paper no. 3251-A).

The first adopted amendment (no. 2) concerns the relationship between the new Act on Restrictive Measures and the existing Act of 13 April 2022 on Special Measures to Counteract Support for Aggression against Ukraine and to Protect National Security.

The amendment primarily clarifies the scope of application of certain provisions of the new Act to matters covered by the 2022 Act, including changes to the statutory cross-references. It also expressly states that measures imposed under the 2022 Act constitute restrictive measures within the meaning of the new legislation.

A total of 242 MPs voted in favour of the amendment, 146 voted against it, and 58 abstained.

The second adopted amendment (no. 6) is a clarification concerning the wording of Article 4(3), which governs the grounds for applying national restrictive measures. It was supported by 244 MPs, while 142 voted against it and 55 abstained.

The remaining amendments presented in parliamentary paper no. 3251-A were rejected. These included proposals to narrow the scope of the legislation, remove some of the provisions on national restrictive measures, and change the rules on providing reasons for and challenging sanctions decisions.

This means that the Sejm retained the core structure of the new sanctions system, including the mechanisms for national restrictive measures and the extensive framework of liability for violations.

The New Sanctions Act — What Will Change for Businesses?

The Act on Restrictive Measures is horizontal in scope. It is not limited to sanctions relating to Russia or Belarus, but covers the system for applying restrictive measures under European Union law, as well as national sanctions instruments.

Among other things, the draft legislation provides for:

• defining the responsibilities of the authorities tasked with applying restrictive measures and monitoring compliance;

• allowing national restrictive measures to be imposed on specified individuals and entities;

• allowing national restrictions to be introduced on certain economic relations with third countries;

• rules on freezing funds and economic resources and prohibiting their availability;

• a system of administrative fines and criminal liability for violating or circumventing sanctions.

The new legislation is also intended to implement Directive (EU) 2024/1226, which lays down rules on criminal liability for violations of EU restrictive measures.

For businesses, it is particularly important to recognise that sanctions risk is not limited to entering into transactions directly with entities included on sanctions lists.

Other relevant factors may include counterparties’ ownership and control relationships, the indirect nature of transactions, the classification of goods, the destination country, and the actual end user.

Penalties for Sanctions Violations — Up to PLN 200 Million or 5% of Revenue

One of the most important elements of the Act passed by the Sejm is a significant tightening of the liability rules for violations of restrictive measures.

Several separate mechanisms of liability are envisaged.

Administrative fines of up to PLN 20 million may be imposed for certain breaches of prohibitions and obligations arising from restrictive measures.

Criminal liability for individuals may include imprisonment of up to 12 years in the most serious cases.

The provisions on the liability of collective entities are also particularly significant. In certain cases, they provide for a financial penalty ranging from PLN 10,000 to PLN 200 million, or 5% of revenue generated in the relevant financial year.

For large businesses and multinational groups, this creates the possibility of very substantial financial consequences.

However, liability will depend on the type of violation, the circumstances of the individual case, and the conditions laid down in the relevant provisions.

Which Businesses Should Pay Particular Attention to the New Act?

Businesses engaged in international trade should pay particular attention to the changes, including manufacturers, importers, exporters, distributors, and logistics and transport service providers.

This applies especially to sectors such as automotive, machinery, electronics, chemicals, metals, and advanced technologies.

In practice, risks may also arise in transactions carried out through foreign distributors or companies belonging to multinational groups.

The mere fact that the direct recipient of goods is based in a country not subject to sanctions does not necessarily mean that the entire transaction complies with the applicable restrictions.

It may also be important to verify the product’s actual destination, its subsequent resale, and the relationships between the parties involved in the transaction.

Businesses should therefore assess whether their existing sanctions compliance procedures cover not only counterparty screening, but also the classification of goods, the analysis of products and their technical specifications, and checks on end use.

When Will the New Act on Restrictive Measures Enter into Force?

The passage of the Act by the Sejm does not mean that the legislative process has been completed.

The next step will be consideration by the Senate, followed by the presidential stage and publication in the Journal of Laws.

Under the text passed by the Sejm, most provisions are intended to enter into force 30 days after publication. A longer, six-month period is envisaged for one provision.

The final date on which the Act will enter into force therefore cannot yet be specified.

However, if the legislative process is completed in 2026, the new rules could take effect as early as the beginning of 2027.

For businesses, the short period between publication and entry into force is particularly important. Once the legislation has been officially published, there may be little time to conduct an assessment and make any necessary adjustments to procedures.

What Should Businesses Do Now?

As a first step, businesses should review their existing transaction and counterparty screening procedures in light of current EU sanctions and the proposed national system.

Particular attention may be required for processes involving the export and import of goods, product classification, identification of intermediaries, verification of counterparties’ ownership structures, and assessment of re-export risk.

It is also important to properly document the checks carried out and establish procedures for responding to identified sanctions risks.

The passage of the Act by the Sejm means that businesses should already be taking the new liability framework into account when planning their compliance activities for 2027.

Economic sanctions are no longer an issue solely for specialist legal teams. In many businesses, they will require close cooperation between procurement, sales, logistics, tax, and compliance departments, as well as those responsible for supply chain management.

Contact

Krzysztof Wiński
Partner, Thedy & Partners
krzysztof.winski@thedy.pl
Tel. +48 519 506 434

Tomasz Orłowski
Senior Manager, Thedy & Partners
tomasz.orlowski@thedy.pl
Tel. +48 519 504 890