The Digital Poland Association (Związek Cyfrowa Polska) has formally urged the European Commission to halt legislative work on the proposed Digital Fairness Act (DFA). In a submission made during the public consultation, the organisation warns that the new legislation would not deliver meaningful benefits to consumers, while regulating areas already covered by existing EU law — ultimately adding to legal complexity, increasing costs for businesses and weakening Europe’s global competitiveness.
“In its current form, the Digital Fairness Act runs counter to the European Commission’s own promises to cut red tape and simplify regulation. Instead of improving enforcement of existing rules, it adds yet another layer on top of the DSA, DMA, GDPR and the AI Act,” the statement reads.
“We call on the Commission to abandon work on new rules and focus instead on effective implementation and enforcement of the laws already in place,” emphasizes Michał Kanownik, President of Cyfrowa Polska.
Enforcement, not more lawmaking
In its statement, the association stresses that the EU already has the world’s most extensive consumer protection framework, including legal instruments such as UCPD, CRD, UCTD, GDPR, and newer regulations like the Digital Services Act (DSA), Data Act and AI Act.
According to Cyfrowa Polska, the proposed DFA duplicates existing rules and risks further fragmentation of the EU single market — creating barriers to cross-border business and increasing the risk of inconsistent national interpretations.
“We do not need yet another piece of legislation — we need consistent oversight and clear guidance for businesses. Only this can ensure fairness and transparency for consumers without stifling innovation,” adds Kanownik.
Duplication of rules and loss of competitiveness
The association cautions that introducing DFA would further complicate the EU’s legal environment, leading to higher administrative and compliance costs — especially for SMEs. Rather than strengthening consumer protection, Cyfrowa Polska warns, the proposal could in fact reduce consumer choice by slowing the development of digital services and personalised solutions used daily by millions of Europeans.
The organisation highlights that many issues the Commission seeks to regulate — such as “dark patterns”, personalised advertising, addictive content design, or influencer practices — are already covered under existing EU law. The real issue is inconsistent, fragmented enforcement, not a lack of regulation.
A call to stop the overproduction of regulation — and focus on execution
In its letter to the European Commission, Cyfrowa Polska states that the decision on the Digital Fairness Act will be a credibility test for the EU’s declared policy of regulatory simplification. The association urges the Commission to suspend the DFA, reinforce enforcement of existing legislation, provide clear, harmonised guidance, and continue to align current rules based on principles of technological neutrality and proportionality.
“Europe needs simple, predictable and coherent legal frameworks that support innovation — not suppress it. If we truly want to increase our competitiveness and resilience, we must focus on simplifying and enforcing existing rules, not multiplying new ones,” concludes Kanownik.
