Financial Ombudsman’s decision imposing record-setting fine overturned
24.08.2026
As announced by Poland’s Financial Ombudsman, in an administrative decision of 22 July 2025 a fine of PLN 600,000 was imposed on the Bulgarian insurance company Insurance JSC DallBogg: Life and Health AD, based in Sofia (DallBogg). That decision was upheld in a further decision by the Financial Ombudsman of 15 September 2025.
In public communiqués, the Financial Ombudsman stressed that the fine was meant to be severe, hence the record-setting amount: “Financial Ombudsman imposes PLN 600,000 fine on DallBogg”; “Financial Ombudsman upholds decision imposing fine on DallBogg.”
Our law firm took over the representation of DallBogg when judicial review was already underway, filing an amended complaint with the administrative court. In the court proceedings and at the hearing, we alleged a number of violations of procedural and substantive law committed by the Financial Ombudsman when imposing the fine against DallBogg.
In the judgment of 20 August 2026 (case no. VI SA/Wa 3459/25), the Province Administrative Court in Warsaw set aside in its entirety the Financial Ombudsman’s decision of 15 September 2025. In the oral justification for the ruling, the court stated that it shared our view that the administrative authority had violated procedural regulations involving the gathering and assessment of evidence in the case. Recognising these violations as sufficient to overturn the challenged decision, the court declined to rule on the other allegations.
The judgment is not yet legally final. If it becomes final, the Financial Ombudsman will be required to reconsider the case and issue a new decision.
The client was represented before the administrative court by adwokat Mateusz Kosiorowski (head of the firm’s insurance practice), and adwokat Marcin Sobkowicz and adwokat Dr Maciej Kiełbowski (administrative proceedings practice), with support from Mateusz Muszyński and Klaudiusz Mikołajczyk (insurance practice).