Is it legal to record a meeting in Poland?

Kodeks karny Art. 267, in the 2025 consolidated text: § 1 obtaining access without authorisation to information not intended for the person, by opening a closed letter, connecting to a telecommunications network, or breaking through or circumventing electronic, magnetic, IT or other special protection of it. § 2 obtaining access without authorisation to all or part of an IT system. § 3 the same penalty for whoever, "w celu uzyskania informacji, do której nie jest uprawniony, zakłada lub posługuje się urządzeniem podsłuchowym, wizualnym albo innym urządzeniem lub oprogramowaniem", installs or uses an eavesdropping, visual or other device or software in order to obtain information to which they are not entitled. § 4 disclosure of information so obtained. § 5 prosecution only on the victim's application. The penalty under § 1 is a fine, restriction of liberty, or up to two years.

A sourcing warning that matters. The 1997 Dziennik Ustaw text has only four paragraphs and puts the device limb in § 2. The paragraph numbering above comes from the current consolidated text, Dz.U. 2025 poz. 383. Any Polish citation must point at the tekst jednolity, or it will be wrong about which paragraph says what.

Generally yes. § 3 targets a device used to obtain information one is not entitled to, and a participant in a conversation is entitled to what is said in it. § 1 requires a closed letter, a network connection or the defeat of a protection measure, none of which describes listening to a meeting you are in.

That is our reading of the text, not a settled position. No Polish decision or commentary was opened in our research, so treat it as an argument from the statutory words rather than as authority. Note also § 4: disclosing information obtained under §§ 1 to 3 is its own offence.

Nothing in Polish criminal law requires you to say anything as a participant. GDPR does, and it wants the information before the substance of the meeting.

Quick note before we start: I'm recording this so I can write my notes up afterwards. It transcribes on my laptop, nothing goes to the cloud, and I only keep the text. Say so now if you'd rather I didn't.

Longer versions, and what to do when someone says no, are on telling people you're recording.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Poland's 2018 monitoring scheme sits in two articles of the Kodeks pracy, and the interesting thing about it is what the first one does not mention.

Art. 22² is video monitoring, and its § 1 is expressly limited to image: the employer may introduce special supervision of the workplace "w postaci środków technicznych umożliwiających rejestrację obrazu", in the form of technical means enabling the recording of image, and only where necessary to ensure employees' safety, protect property, control production, or keep secret information whose disclosure could expose the employer to harm. §§ 6 to 9 carry the procedure: purposes, scope and manner set out in the collective agreement, the regulamin pracy or an announcement; employees informed no later than two weeks before it goes live; written information to each employee before they start work; and monitored premises marked visibly and legibly no later than one day before it starts. § 3 caps retention of image recordings at three months.

Art. 22³ § 4 is the provision that reaches anything else: "Przepisy § 1–3 stosuje się odpowiednio do innych form monitoringu niż określone w § 1, jeśli ich zastosowanie jest konieczne do realizacji celów określonych w § 1." The email-monitoring rules apply accordingly to other forms of monitoring, where necessary to achieve the purposes in § 1: organising work so that working time is fully used, and ensuring the proper use of the work tools provided.

So audio has no basis in the video-monitoring provision at all, and can only come in through Art. 22³ § 4, whose permitted purposes are narrow and whose test is necessity. Continuous audio capture of meetings is a hard fit for either purpose. That reading is ours rather than a regulator's, and on it Poland is among the more hostile jurisdictions to an employer-deployed always-on microphone while remaining permissive for an individual participant.

Nothing we can cite, and there is a specific claim to withdraw rather than repeat. A UODO position that workplace monitoring may not record sound circulates widely, including in an earlier draft of our own research. We could not verify it: uodo.gov.pl has no reachable search and the document URLs tried all returned 404. Do not attribute that position to UODO.

The statutory argument above does the same work and can be checked, which is why this page rests on it instead.

Because the binding layer in Poland is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Kodeks karny, consolidated text Dz.U. 2025 poz. 383 (Art. 267)
• Kodeks pracy, consolidated text Dz.U. 2025 poz. 277 (Arts. 22² and 22³)
• Kodeks karny, ISAP landing page
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.