Online video advertising for wellness and complementary therapies in Poland

Healthcare activity: factual information must not become advertising

Legal requirement — paraphrased

Applies when: The message concerns healthcare activity; this is conditional for diagnostics, digital health, aesthetic procedures and wellness.

Where the offer is healthcare activity, Article 14 requires public information about the scope and types of services, while prohibiting advertising characteristics in its content and form. This applies to registered providers and professional practices; payment for a placement does not remove the restriction.

Editorial approach: start with identity, actual qualifications, service scope, location, access and neutral practical information. Have persuasive slogans, superiority claims, discounts and urgency devices assessed against the statutory restriction; do not present them as routinely permitted.

Sources: Healthcare Activity Act — consolidated text, Dz.U. 2026 item 156 · Article 14

Wellness is not a shortcut around healthcare or product rules

Editorial overview

Classify the actual offering rather than its wellness branding. General relaxation or lifestyle services remain subject to truthful consumer marketing. Healthcare activity triggers Article 14; a regulated device or food supplement adds its own rules.

Do not claim that an unsubstantiated complementary method cures disease or replaces necessary care. As an editorial control, explain practitioner qualifications and limits, avoid fear-based sales, and distinguish tradition or personal experience from demonstrated therapeutic efficacy.

Sources: Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845; Healthcare Activity Act — consolidated text, Dz.U. 2026 item 156; GIS — Food labelling, presentation and advertising · Unfair-practices Act Articles 4–7; Healthcare Activity Act Article 14

Device-based services can trigger a second advertising regime

Legal requirement — paraphrased

Applies when: The message advertises a device-based service within Article 58; assess the exact creative.

Device-advertising rules extend to business/professional services to the extent they concern services provided using a device, including rental. They also cover remunerated user opinions. A clinic's own account and a paid creator are not exempt.

Before showing equipment or device-based treatment benefits publicly, assess the lay-user restriction and healthcare-professional presentation restriction. For qualifying public advertising, check the identity, warning and format requirements in the device advertising regulation. Ordinary service information is not automatically device advertising.

Sources: Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620; Medical-device advertising regulation — Dz.U. 2023 item 817 · Device Act Article 58(1); advertising regulation sections 2–4

Include device identity and the correct Polish warning

Legal requirement — paraphrased

Applies when: The exact message is public device advertising, including qualifying device-based service advertising under Article 58.

Apply this module only to qualifying public device advertising, including a device-based service falling within Article 58. It does not make an otherwise prohibited advertisement permissible.

For public device/IVD advertising, identify the advertiser, manufacturer and appointed authorised representative, alongside device name and intended purpose. The warning is: To jest wyrób medyczny. Używaj go zgodnie z instrukcją używania lub etykietą.

For Annex XVI non-medical-purpose products and device accessories, the regulation instead specifies: Dla bezpieczeństwa używaj zgodnie z instrukcją używania lub etykietą. Determine the correct branch before drafting.

Sources: Medical-device advertising regulation — Dz.U. 2023 item 817; Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620 · Sections 1–3

Fit device warnings to image, audio or video

Legal requirement — paraphrased

Applies when: The exact message is public device advertising, including qualifying device-based service advertising under Article 58.

Apply this module only to qualifying public device advertising, including a device-based service falling within Article 58. It does not make an otherwise prohibited advertisement permissible.

Audiovisual: warning in the bottom 15% or more, clearly spoken in Polish for at least four seconds. Audio: at least four seconds of clear Polish warning. Visual: bottom 10% or more, on the first page of multipage advertising. Observe the prescribed contrast, static horizontal text and spacing.

Sources: Medical-device advertising regulation — Dz.U. 2023 item 817; Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620 · Section 3(3)

Protect patients before using stories, images or testimonials

Editorial overview

Applies when: Patient information or identifiable treatment material is used.

Do not assume treatment consent authorises a public case study, testimonial or before/after photograph. Check confidentiality, privacy and a separate lawful basis for the proposed disclosure, including health data; public responses to reviews must not reveal confidential treatment details.

Editorial safeguard: obtain a specific, voluntary publication permission for the intended material and channels, assess identifiability even when the face is hidden, and check that refusing publicity does not affect care. Publication permission cannot cure unlawful advertising or misleading outcome claims.

Sources: Patient Rights Act — consolidated text, Dz.U. 2024 item 581; Regulation (EU) 2016/679 — General Data Protection Regulation · Patient Rights Act Articles 13–14 and 20; GDPR Articles 5–7 and 9

Make the overall message truthful and commercially identifiable

Legal requirement — paraphrased

Misleading claims, material omissions, hidden commercial intent and aggressive consumer marketing are prohibited. Assess visuals, comparisons, qualifications and the impression on vulnerable consumers. Do not falsely claim that a product cures illness.

Editorial control: retain substantiation before publication, remove fabricated urgency or authority badges, and check that qualifications do not contradict the headline. Paying to publish apparently independent advice must not conceal its commercial nature.

Sources: Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845 · Articles 4–9; Article 7 hidden advertising and false cure claims

Check price reductions only after establishing that promotion is lawful

Legal requirement — paraphrased

Where an advertisement announces a reduction for a good or service, state the relevant lowest price from the preceding 30 days alongside the reduced price. For a shorter selling history, use the lowest price since sales began; special rules apply to rapidly perishable goods.

This consumer-information rule does not permit a discount or purchasing incentive prohibited by medicine or service rules. As an editorial check, make the total scope and extra charges clear.

Sources: UOKiK — Information about price reductions · Price Information Act Article 4 as explained by UOKiK

Keep reviews genuine and explain verification

Legal requirement — paraphrased

Do not publish, commission or distort false consumer recommendations. If making consumer reviews available, explain whether and how their origin is verified. Do not claim authentic-user verification without reasonable, proportionate checks.

Selecting a patient or customer story for advertising also requires checking the sector's claims and endorsement restrictions. A genuine testimonial can still contain an unlawful health claim.

Sources: UOKiK — False reviews? Stop!; Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845 · Unfair-practices Act Articles 6–7; UOKiK reviews guidance

Keep health data out of routine advertising workflows

Legal requirement — paraphrased

Establish a lawful processing basis, transparency and purpose limits. Health/genetic data also require a valid Article 9 condition; a treatment relationship does not automatically justify marketing reuse. Honour direct-marketing objections and withdrawable consent.

Editorial safeguard: keep symptoms, diagnoses, test results and appointment details out of advertising pixels, URLs, audience uploads and creator briefs unless a separately assessed lawful arrangement permits the processing.

Sources: Regulation (EU) 2016/679 — General Data Protection Regulation · Articles 5–7, 9, 13–14 and 21

Assess cookies, pixels and device access separately

Legal requirement — paraphrased

Prior information and consent are required for terminal storage/access unless a statutory exception applies, such as what is necessary for transmission or a service requested by the user. Ordinary advertising tracking should not be treated as necessary merely because it funds the website.

As an implementation control, test the consent mechanism before loading advertising tags and keep the privacy-processing assessment separate from the cookie-consent check.

Sources: Electronic Communications Law — Dz.U. 2024 item 1221 · Article 399

Review sound, images and promotional excerpts together

Editorial recommendation

Apply sector audiovisual rules to promotional videos, including short clips and creator reels. Silent edits, thumbnails and excerpts need their own format assessment. Reserve adequate warning space and duration before production; a description link does not replace an in-video requirement.

Assess whether the provider/channel is a regulated audiovisual media service or a video-sharing-platform placement. Those regimes can add ad identification, sponsorship and placement rules; not every individual upload has identical broadcaster duties.

Sources: Medicine advertising regulation — consolidated text, Dz.U. 2023 item 1648; Medical-device advertising regulation — Dz.U. 2023 item 817; Broadcasting Act — consolidated text, Dz.U. 2022 item 1722 · Sector audiovisual provisions; Broadcasting Act Articles 47c and 47q

Keep one campaign evidence and approval record

Editorial recommendation

Recommended workflow: record the exact offer and legal classification, advertiser, selected channel and creative formats; list permitted claims and evidence; review the Polish execution and destination; record sign-off, publication and corrections.

Keep the source date with the rule. Recheck legislation flagged as changing, especially pharmacy advertising. Preserve statutory archive periods where they apply; this suggested general workflow does not create a universal retention period.

Sources: URPL — Advertising medical devices; Sejm official API — Pharmacy advertising amendment, process 3002 · Specific retention and legislative-watch sources; workflow is editorial