• Unwanted subscriptions and unexpected charges on your phone bill? The President of UOKiK has obliged the operator to change the “Order with T-Mobile” [“Zamów z T-Mobile”] service.
• No more one-click traps. T-Mobile will introduce additional confirmations, provide clear information about prices, and change the way it responds to complaints.
• Consumers will receive a refund of unduly charged fees and compensation of PLN 500.

Mobile internet phones allow users to purchase digital content with a single swipe of their finger. However, this convenience can backfire if the system does not give consumers full control over what they are actually ordering. Proceedings conducted by the President of UOKiK revealed that, in the case of the “Order with T-Mobile” service, customers sometimes received bills for subscriptions to which they had not consented. As a result, the President of UOKiK imposed an obligation on T-Mobile to introduce changes to this service. Billing is to become fully transparent, and consumers are to regain control over it.

– A subscription should always be a conscious decision by the consumer, not the result of chance or a technical trick. Consumers should not discover later that “something was activated”. They have the right to full control over their bills. I have obliged the operator to make changes that should prevent the launch of paid services without the explicit consent of consumers. Everyone must have clear information about what they are ordering, how much they will pay, who is providing the service, and how to cancel it – says Tomasz Chróstny, the President of UOKiK.

How did the service work?

“Order with T-Mobile” is an optional billing service, also known as direct billing. It allowed users to pay for digital content – such as games, entertainment services, or videos – by adding the fee to their phone bill. The providers of such content were external companies, including Vodonline, Wizzgames, Gameland, and Zaplium. T-Mobile acted as an intermediary in collecting payments.

In practice, the service could deprive consumers of real control over what they were activating. On devices using data transmission, the phone number was automatically read on the content provider’s website, and no purchase authorisation was required. This meant that visiting a gaming or music website, or accidentally clicking on an advertisement, could result in the activation of a paid subscription without the user’s explicit consent.

The problem was particularly acute for people who used SIM cards in routers rather than in phones. In such devices, automatic number reading worked the same as in a phone, but the consumer had no way of knowing that they had activated a service. Informative text messages were sent to the SIM card in the router, but the messages could not be read on the device screen. Moreover, many LTE modems cannot be used to send a “STOP” reply message, so users did not have the technical ability to cancel the subscription immediately. As a result, some people may not even have known that they had been signed up for a paid service until they received their phone bill.

This was compounded by other irregularities. Consumers did not receive confirmation of the terms and conditions of the “Order with T-Mobile” service itself, even though these were the basis for charging fees. Charges were presented in a general manner on bills, without indicating the name of the service or content provider, making it impossible to determine the origin of a given item. Responses to complaints often did not explain how the service was activated, and some customers were referred to intermediaries rather than receiving full information from the operator. As a result, the entire mechanism – from activation, through information about terms and conditions, to complaint handling – operated in a way that could lead to charges for subscriptions ordered unknowingly.

Safer activation and compensation for consumers

In the course of the proceedings, T-Mobile introduced certain beneficial changes to the service, including the requirement for authorisation using a PIN code. However, the decision of the President of UOKiK obliges T-Mobile to implement a transparent and secure service activation process based solely on the conscious action and consent of the consumer. This involves independently entering the telephone number, receiving and entering an SMS code, and explicitly confirming the order. Each stage will be verified by the operator to eliminate accidental activation of subscriptions.

The second key element of the decision is financial compensation for people who incurred costs related to the operation of the service between 2018 and 2024. Consumers who activated any service using “Order with T-Mobile” during this period and whose complaints were rejected or only partially upheld will receive a one-off payment of PLN 500. Persons who used the Vodonline, Wizzgames, Gameland, or Zaplium services and then deactivated them within 60 days, but did not receive a refund earlier, can claim a refund of the fees charged for that period.

T-Mobile will inform eligible consumers about compensation – current subscribers by text message, and former subscribers by letter or e-mail. It will also offer various payment options depending on the status of the eligible person, including bank transfer, postal order, or bill reduction. Compensation will be paid after the decision of the President of UOKiK becomes final.

Actions against telecoms

These are not the only actions taken by UOKiK in the telecommunications market concerning direct billing services provided by operators. In connection with the entry into force of the Electronic Communications Law, the President of UOKiK is reviewing the terms and conditions under which operators have implemented regulations governing optional account debiting services.