Do you run a channel, publish reels, or leave stream recordings for viewers? You can be an on-demand audiovisual media service provider, even if you don't have your own platform and operate solely on social media. In such a case, Article 47ca of the Broadcasting Act requires the service to be registered with the Chairman of the National Broadcasting Council (KRRiT). Below, I explain who this obligation applies to, how to comply with it, and the consequences of ignoring it.
Most importantly: there is no statutory threshold for followers. The method of running an account and its connection to business activity determines its entry, not the reach of a given creator.
What is the list of on-demand audiovisual media services?
The List of Audiovisual Media Services on Demand (VOD) is a public list of service providers where viewers can choose the video content and when to watch it. It is maintained by the Chairman of the National Broadcasting Council. The basis for entry is a submission submitted by the creator or company responsible for the service.
This is not a license or consent for every subsequent video. The National Broadcasting Council (KRRiT) does not approve content before publication and does not take over the management of the channel. Submission itself is free of charge. In the public directory, the KRRiT generally publishes the name and details of the provider and the name of the service, for example, the name of the YouTube channel.
Why might a VOD listing apply to an influencer?
A VOD service doesn't have to run on a website like Netflix. According to the National Broadcasting Council (KRRiT), a catalog can also be a channel or profile on a social media platform. The creator selects films, publishes them, removes them, groups them into series or playlists, and thus exercises editorial control over the catalog.
Therefore, the requirement to list content on YouTube, TikTok, Instagram, or Facebook may apply. It may also apply to recordings of broadcasts and clips on Twitch or Kick, provided viewers can later select the content and replay it at their convenience. A broadcast viewed exclusively live is not considered an on-demand service, but a recording of it available later may be.
Who must register the service with the National Broadcasting Council?
The obligation arises when the creator's activity meets the statutory characteristics of both a media service and a VOD service. In practice, it's worth reviewing seven questions.
Quick test: VOD service features must be assessed together
| Condition | What to check on your account |
| Polish jurisdiction | The creator or company lives or is based in Poland and decisions about content are made here. |
| Economic activity | Video is an element of the creator's profitable, organized and continuous activity. |
| Media target | The primary purpose of a profile or a separate section thereof is to inform, educate or entertain. |
| Public access | The materials are intended for general audiences, even when access requires a fee or subscription. |
| Watch on demand | The viewer himself chooses the film and the moment of its playback. |
| Catalog | A channel, profile, video library, series, or playlist creates an organized collection of content. |
| Editorial control | The creator decides what to publish and how to arrange the materials in the catalog. |
If even one element raises doubts, an assessment of the specific profile is needed, not just the platform name.
Does a business have to generate money?
The VOD service must be provided as part of a business activity conducted in this area. Typically, this will be evidenced by revenue from platform advertising, collaborations, subscriptions, paid access, donations, affiliations, or the sale of own products and services related to the content. The mere lack of revenue in a given month does not necessarily exclude the obligation if the channel is part of the creator's organized business.
The National Broadcasting Council (KRRiT) indicates that registration is not required for individuals operating solely for personal or hobby purposes, or for those conducting unregistered business activity pursuant to Article 5 of the Entrepreneurs' Law. As of January 1, 2026, the limit for this activity is quarterly. In 2026, the income due cannot exceed PLN 10,813.50 in any quarter, provided the individual has not conducted business activity in the last 60 months. This is an exception that must be assessed carefully, especially if the creator already has a registered company.
Does the number of followers matter?
No. The Act does not impose minimum followers, views, or revenue requirements specific to the VOD list. A small but professionally run channel may be eligible for inclusion. A large hobbyist channel may require a different assessment if it is not run as part of a business.
When is entry on the list not usually necessary?
In particular, the following situations may be outside the scope of the obligation:
- the account is truly private or hobby in nature and is not part of a business activity;
- the person meets all the conditions for unregistered activity, including the income limit and the condition of not conducting business activity for the last 60 months;
- the videos are only a supplement to another activity, and providing informational, entertaining or educational content is not the main purpose of the profile or any separate part thereof;
- the materials are not publicly available to all users, but are shared within a closed, private circle;
- the creator only broadcasts live, with no catalog of recordings or clips available later on demand.
How and when to make an entry?
The application must be submitted no later than 14 days before the service becomes publicly available. The form and instructions are available on the KRRiT website. Entry is made by decision of the KRRiT Chairman.
To get an entry:
- Make a list of your services. Separately describe each channel or profile where you share a catalog of video content.
- Complete the form. Provide the creator or company details, Tax Identification Number (NIP) and National Business Registry Number (REGON), name of the service, method of provision, delivery model, and the countries where it can be received.
- Sign and submit the application. When submitting via electronic mailbox, use a trusted profile or a qualified signature.
- Keep your records up-to-date. Changes to the data listed must be reported within 14 days of their occurrence.
Multiple services can be listed in a single report, but the National Broadcasting Council (KRRiT) evaluates them separately and issues a separate decision for each. If the channel is already operating without a report, the statutory deadline cannot be extended. The safest course is to immediately assess the account balance, submit a valid report, and prepare documentation demonstrating the date and model of service operation. A later report limits the duration of the violation, but does not automatically eliminate the risk of penalties for the earlier period.
What is the penalty for not being included in the VOD list?
For violations of Article 47ca, paragraph 1, the Chairman of the National Broadcasting Council may impose an administrative fine. The maximum fine is twenty times the average monthly salary in the corporate sector, including profit distributions, in the quarter preceding the decision.
Current example: for a decision issued in the third quarter of 2026, the maximum fine is PLN 187,926.60 (20 x PLN 9,396.33). The maximum limit changes every quarter.
The maximum penalty is not an automatic penalty in every case. When determining its amount, the authority takes into account the scope and severity of the violation and the provider's previous activity. However, a penalty may be imposed again if the violation is not remedied within 30 days of the previous penalty being paid. A decision cannot be issued after two years have passed since the violation.
This isn't a dead letter. In its 2025 report, the National Broadcasting Council (KRRiT) reported that it had issued 45 decisions imposing financial penalties for failure to register on the VOD register. In one case reported by the KRRiT, involving an influencer running a YouTube channel, the fine was PLN 10,000 and was ultimately collected by the tax office.
Does legitimate interest replace consent to email or telephone?
No. Registration is the beginning of a VOD provider's obligations, not the end. Depending on the content and operating model, you must, among other things:
- provide the supplier’s identification and contact details on the profile and indicate the National Broadcasting Council as the competent authority;
- correctly label commercial communications, sponsorship and product placement;
- qualify and mark materials that may have a negative impact on minors and apply the required safeguards;
- retain copies of programmes for at least 28 days after they have ceased to be made publicly available;
- submit an annual report for the previous year by 31 March.
The scope of these obligations depends on the specific channel. Therefore, before reporting, it's worth conducting a brief audit of profiles, advertising content, age ratings, and how materials are archived.
What should an author do if he or she does not know whether he or she is subject to registration?
First, separate each channel and profile you manage, then evaluate them against the seven criteria in the table. Don't base your decision solely on follower count or the fact that the platform is owned by a foreign company. With multiple accounts, a company-owned business, streams combined with videos, or social media sales, the assessment may require a broader analysis of the entire business model.
Graś i Wspólnicy can verify which profiles are eligible for registration, prepare a report, and manage other VOD obligations. See our range of support in the areas of compliance and copyright, meet our team , or contact us.
FAQ - most frequently asked questions from developers
Does every influencer have to be included in the KRRiT list?
No. The obligation applies to creators whose accounts meet all the characteristics of a VOD media service and are operated as part of a business. A purely private or hobby account is generally not subject to registration.
Does a small number of followers excuse you from posting?
No. The Act does not specify a threshold for followers or views. Even a small channel may be eligible for registration if it is a professionally run video catalog for profit.
Can a TikTok or Instagram account be a VOD service?
Yes. Short videos can also be standalone audiovisual programs, and a profile can function as a directory. The characteristics of a specific account are decisive, not the length of the recording or the platform name.
Does a Twitch or Kick streamer need to sign in?
A broadcast available exclusively live is not considered on-demand. However, if recordings of the broadcast or clips remain on the profile for viewers to select and watch later, this part of the activity may meet the characteristics of VOD.
Is there a fee for entry into the VOD list?
No. The National Broadcasting Council confirms that submission is free of charge. Entry is not a license and does not constitute approval of the films prior to publication.
Can multiple channels be submitted together?
Yes, multiple services can be listed in a single application. However, the National Broadcasting Council evaluates each service separately and issues a separate entry decision for each.
What to do if the channel is already working without an entry?
It's not worth waiting for a notice. You need to quickly determine when your account meets VOD criteria, submit the correct application, and sort out any further obligations; a late entry does not automatically remove liability for the earlier period.
Does the entry affect tax or social security contributions?
No. The National Broadcasting Council clarifies that entry on the register does not change the creator's tax or insurance obligations. These matters are still assessed according to tax and insurance regulations.
Summary
If you run a creative business and publicly share a structured catalog of films that viewers watch at a selected time, you should check the VOD listing requirement. Don't wait for the National Broadcasting Council (KRRiT) to inquire about the matter: reporting is free, and the penalty for failure to do so can be significant. The greatest risk arises when the creator treats the channel like a business, but the paperwork remains a hobby.
Need a quick assessment of your accounts or assistance with filing a claim? Schedule a consultation with Graś i Wspólnicy Law Firm.
Basics and sources
- The Broadcasting Act – in particular Article 4, points 1-4, 6a and 8a, Article 47ca and Article 53c
- KRRiT: obligation to register on-demand audiovisual media services
- KRRiT: guide for influencers
- Central Statistical Office: average salary in the enterprise sector in the second quarter of 2026.
- KRRiT: activity report for 2025.
- KRRiT: PLN 10,000 fine enforced for failure to enter the influencer's service into the VOD register
- Biznes.gov.pl: unregistered business and income limit in 2026
This article is for informational purposes only and does not constitute legal advice
Legal status as of August 25, 2026.
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