The digital environment has long become one of the main places of consumption. Goods are ordered through applications and online stores, films and music are accessed through streaming platforms, while many services operate exclusively online.

For this very reason, the new Consumer Protection Law significantly expands and clarifies the rules relating to the digital market. The focus is no longer only on the traditional purchase of goods, but also on digital content, digital services, applications, online marketplaces, the ranking of offers, reviews and updates.

Below, we highlight some of the most important changes that may be relevant both to consumers and to traders and providers of digital services.

Online Marketplace

One of the most important changes concerns online marketplaces, namely services using software, websites or applications operated by or on behalf of a trader, which allow consumers to conclude distance contracts with other traders or consumers. In practice, these may include online platforms for the sale of goods and services, applications facilitating purchases, advertising and sales websites, as well as other digital spaces connecting sellers and buyers.

This change is significant because an online marketplace is usually not the seller of the goods or services, but a platform enabling the conclusion of a contract between a consumer and another trader or consumer. It is therefore important for the consumer to know who is behind the offer and who is responsible for fulfilling the contractual obligations.

Before the consumer is bound by a contract or an offer, the platform must clearly inform the consumer whether the seller is a trader or a private individual acting outside their business activity. If the seller is not a trader, the consumer must be informed that the provisions of the Consumer Protection Law do not apply to such a relationship.

In addition, the platform must indicate how the contractual obligations are divided between the platform and the person making the offer. For example, it should be clear to the consumer who is responsible for delivery, complaints, refunds or other contractual obligations. This information cannot be hidden solely in the general terms and conditions, but must be presented in a clear and understandable manner.

Ranking of Offers

In digital commerce, the order in which products are displayed has a significant influence on consumers’ decisions. Products appearing at the top of search results are often perceived as the most relevant, most affordable or highest-quality products.

However, the ranking of offers may depend on various factors, such as paid advertising, product popularity, user ratings, product availability or the platform’s algorithmic assessment.

The Law therefore introduces an obligation of greater transparency regarding the main parameters determining the ranking. Consumers must be informed why certain offers are displayed in a particular order and which criteria have a decisive influence on their visibility.

It is particularly important that paid advertising or paid higher placement in search results is clearly indicated. In other words, the impression must not be created that a particular offer is displayed as the most relevant based on search criteria if its position is the result of paid promotion.

Consumer Reviews

Reviews have become one of the most important factors in online shopping, particularly where the purchase does not involve a physical inspection of the product.

The Law therefore introduces clearer rules in this area as well. If a trader provides access to consumer reviews, the consumer must be informed whether the trader verifies that the reviews were actually submitted by consumers who purchased or used the product, as well as how such verification is carried out.

A trader must not claim or create the impression that reviews are authentic if reasonable verification measures have not been taken. Submitting or commissioning false reviews and endorsements, as well as presenting them in a manner that misleads consumers as to their origin or authenticity, is considered a misleading commercial practice.

Digital Content and Digital Services

In addition to the rules relating to online sales and platforms, the new Law regulates digital content and digital services much more clearly. These rules may apply to applications, software, cloud services, streaming platforms, video games, e-books, digital courses and other similar content.

The basic principle is that digital content or a digital service must correspond to what was presented to and agreed with the consumer. If a particular functionality, quality, method of access or demo version was presented to the consumer, the content or service supplied should correspond to that presentation.

If digital content or a digital service fails to meet the agreed requirements or does not correspond to what was presented to the consumer, the consumer may have the right to request that the non-conformity be corrected, to obtain a price reduction, or to terminate the contract, depending on the nature of the issue and the circumstances of the specific case.

Updates also play an important role in relation to digital content and digital services. The trader is required to inform the consumer of necessary updates, including security updates, and to provide them during the period in which the consumer may reasonably expect them. On the other hand, if the consumer fails to install an update within a reasonable period after being duly informed, the trader will not be liable for a problem arising solely from that failure.

Another important change is that the Law recognizes that digital content or digital services are not always paid for with money. Where the consumer provides personal data in return, such a relationship may also be covered by consumer protection rules, except where the data are processed exclusively for the purpose of supplying the digital content or service or complying with legal obligations.

Commencement of Application

The new Consumer Protection Law will apply from 1 August 2026. Although the Law aims to ensure greater transparency, the question remains as to how certain obligations will be implemented in practice. It will be particularly challenging to find a way to present clearly and in a timely manner all the information that traders and online platforms will be required to provide to consumers.

This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.