Record-low rate of complaints against decisions of the President of the Personal Data Protection Office being upheld

In 2025, the courts overturned only 39 of the 205 complaints examined against administrative decisions issued by the President of the Personal Data Protection Office. This means that only 19.02% of these complaints were upheld by the Voivodeship Administrative Court. This result is better than that recorded in 2023, which had previously been the best year in this respect. In 2023, the courts upheld 37 of the 189 complaints against decisions of the President of the Personal Data Protection Office, representing 19.58%. Given the record number of administrative decisions issued by the President of the Personal Data Protection Office in 2025 (more than 2,000), this indicates that the Office’s increased operational efficiency (25% more decisions were issued following administrative proceedings than in the previous year) has been accompanied by a high level of substantive quality in the decisions issued by the supervisory authority responsible for personal data protection.

In 2025, administrative courts received 334 complaints against decisions, orders, actions and acts of the President of the Personal Data Protection Office (as referred to in Article 3(2)(1)–(4) of the Law on Proceedings before Administrative Courts), most of which concerned administrative decisions. This was just one fewer than in 2023, the record year in this respect. In 2024, by contrast, the courts examined as many as 296 complaints - more than the number received that year, which was only 225. A total of 70 complaints were upheld, representing 23.65%. A similar result was recorded in 2022: of the 289 complaints filed, the courts examined 254 and upheld 63, or 24.8%.

The highest number of complaints was upheld in 2021, when the courts upheld as many as 72 out of 192 complaints examined, representing 37.5%. A total of 302 complaints were filed that year. The number of complaints filed was driven primarily by the pandemic, which caused considerable disruption in the area of personal data processing, not least as a result of the widespread shift to remote working. However, the pandemic also contributed to greater public awareness of individual rights. Since then, the number of complaints against rulings issued by the President of UODO has remained close to 300 per year.

In the first years following the GDPR’s entry into force, the number of complaints was considerably lower and did not exceed 200. In 2020, 177 complaints were filed, 107 were examined, and 23 were upheld, representing 21.5%. In the previous year, 161 complaints were filed, 68 were examined, and only 15 were upheld, representing 22.06%. Inevitably, 2018—the year in which the GDPR became applicable, and only from the end of May - recorded the lowest figures in this respect. A total of 56 complaints were filed, while 81 were dealt with (including complaints against rulings issued by the Inspector General for Personal Data Protection), and the courts upheld 18 complaints. Nevertheless, the proportion remained comparable to that of subsequent years, at 22.22%.

We encourage you to read the full 2025 Annual Report of Mirosław Wróblewski, President of the Personal Data Protection Office: https://uodo.gov.pl/pl/138/4555