The Résumé Trap
A Polish watchdog, a Puerto Rican company, and the global reckoning with subscriptions that are easy to start and hard to see.
It is a weekday evening in Warsaw, and someone needs a job. She has spent the past hour inside an online résumé builder called InterviewMe: choosing a template, typing in her work history, accepting the software’s polite suggestions about verbs. The document on the screen finally looks like the person she would like to be on paper. She clicks the button that says “Download your CV.” What appears instead is a screen inviting her to unlock all features, with two prices attached: 5.95 złoty, about a dollar and a half, for fourteen days, or 79.90 złoty, roughly twenty dollars, for a quarter. In smaller type, on a gray background, the site mentions that after fourteen days the fee will renew automatically, every four weeks, at many times the introductory price. She is tired, the résumé is finished, and a dollar and a half is nothing. She pays.
That screen, or, more precisely, its placement at the very end of the user’s journey, is what Poland’s consumer watchdog has now put a price on. On December 29th, the President of UOKiK, the country’s office of competition and consumer protection, fined BOLD LLC, the company behind InterviewMe, seven hundred and sixty-four thousand złoty, roughly two hundred thousand dollars, for a practice that violates the collective interests of consumers. The office was careful about what it was not saying. Freemium, the model in which the tool is free and the result is not, remains perfectly legal. The offense was one of omission: the company failed to tell users clearly, unambiguously, and in good time that downloading or printing the document they had just built required a subscription, and that the subscription would keep charging them until they cancelled it. BOLD has appealed, and the decision is not yet final. Its logic, though, travels well beyond Poland.
The case file reads like a taxonomy of the genre. More than eighty consumers complained to the office, describing the same arc: a small initial charge, then recurring debits discovered on a bank statement. The terms of service, though lengthy, contained no prices at all; the pricing details lived in F.A.Q. sections at the bottoms of pages. When the company made adjustments, in 2024 and 2025, adding a pricing subpage, a renewal notice above the “Continue” button, and a free download option, the regulator was unimpressed. The free download came as a TXT file, stripped of the template, the colors, and the layout that were the reason anyone used the builder in the first place: a fig leaf rendered in plain text. “The consumer has the right to know the price before using a service,” Tomasz Chróstny, the office’s president, said in announcing the decision, and he noted whom the practice touched: people looking for work, often in a hurry, often in some degree of trouble.
Everything turns on a phrase in Polish law that requires material information to be given in good time. When, exactly, is that? The company’s defense is not frivolous. The prices were visible before any money changed hands. After the 2025 changes, the renewal notice sat directly above the payment button. European law has blessed the basic architecture: in 2023, in a case called Sofatutor, the E.U.’s highest court held that a free trial rolling into a paid, auto-renewing subscription is permissible, and generates only a single right of withdrawal, provided the consumer was informed clearly and expressly at the moment of ordering. And Polish courts have shown a willingness to trim the regulator’s enthusiasm; in a case involving the resale platform Vinted, the court that hears appeals from UOKiK struck down part of a similar decision about the timing of fee disclosures.
The weakness in that defense is precisely where the office aimed. The consumer’s decision, the regulator reasoned, is not made at the checkout; it is made at the button that says “Create your CV,” when she decides whether to invest an hour of her evening in this tool rather than another. Behavioral economists have a name for what happens next, the sunk-cost effect, and the decision cites it openly: a person who learns the price after the work is done is far more inclined to pay than one who knew it before she began. The terms of service, meanwhile, could not carry the disclosure, because they contained no prices to disclose. Sofatutor cuts both ways: it protects the merchant who is clear at the door and condemns the one who is not. My own reading, offered as a judgment rather than a certainty, is that the core of the decision is likely to survive on appeal, though Vinted is a reminder that the scope of the finding, or the size of the fine, may yet be adjusted.
There is also the matter of the return address. BOLD LLC is registered in Guaynabo, Puerto Rico, and throughout the proceedings it maintained that it had not submitted to the Polish regulator’s jurisdiction. The argument was never going to work. Polish consumer law, like most consumer law, reaches practices that produce effects on Polish territory, wherever the company keeps its charter; a service operated in Polish, aimed at people seeking jobs in Poland, and generating complaints from Polish consumers qualifies on any reading. Guaynabo is a long way from Warsaw; the internet, inconveniently for BOLD, is not. Whether Poland can actually collect is a different question. The fine binds the Puerto Rican parent, not its Warsaw marketing subsidiary, and American courts have a long tradition of declining to enforce foreign penalties. The decision’s real force lies elsewhere: in the order to publish it on the site’s home page once it becomes final, in its value as a ready-made finding for individual consumers’ lawsuits, and in its visibility to the E.U.’s consumer-protection coöperation network, where a Polish precedent can become everyone’s precedent.
None of this is a Polish eccentricity. Regulators on both sides of the Atlantic have spent the past several years dismantling the same machine: easy entry, hidden recurrence, difficult exit. The largest reckoning involved Amazon Prime. The Federal Trade Commission sued Amazon in June, 2023, alleging that the company enrolled consumers in Prime without clear consent and then deliberately complicated cancellation; the internal code name for the cancellation flow was Iliad, an epic about how hard it is to get home. The settlement, announced on September 25, 2025, days into trial, came to two and a half billion dollars: a billion-dollar civil penalty, the largest ever imposed for violating an F.T.C. rule, plus a billion and a half in refunds, up to fifty-one dollars per customer, covering June, 2019, through June, 2025; the first refunds went out that November and December. The legal foundation was ROSCA, a 2010 statute that requires clear disclosure, express consent, and a simple way out.
Adobe’s turn came next. A federal complaint filed in June, 2024, took aim at the company’s “annual paid monthly” plan: the monthly installment in the foreground, the yearlong commitment and an early-termination fee of half the remaining payments tucked into fine print and hover-over tooltips. This past April, a judge approved a hundred-and-fifty-million-dollar settlement, half penalties and half services for affected customers, along with obligations to disclose the fee up front and to remind users before a trial converts. Epic Games had already paid two hundred and forty-five million dollars in refunds over manipulative billing in Fortnite. And Uber is currently defending its Uber One subscription against the F.T.C., which alleged, in April, 2025, that cancelling could require navigating as many as twenty-three screens and thirty-two separate actions; twenty-one states and the District of Columbia joined the suit in December, seeking civil penalties. Uber denies the allegations, and the case is pending.
The American rulebook itself has had a turbulent run. The F.T.C.’s click-to-cancel rule, finalized in 2024, would have required, among other things, that ending a subscription be as easy as starting one. On July 8, 2025, the Eighth Circuit vacated it in its entirety, in Custom Communications v. F.T.C., on purely procedural grounds. The agency did not retreat; in January it began the process of reissuing the rule, and in the meantime it enforces ROSCA case by case. The paradox, for businesses, is that losing the rule lowered nothing: the risk simply moved from a regulation to a docket.
Europe has been converging on the same principle from the other direction. After complaints from consumer organizations, including Norway’s consumer council, and a coördinated action by the European Commission, Amazon committed that, as of July, 2022, cancelling Prime anywhere in the E.U. would take two clicks on a clearly labelled button; Didier Reynders, then the E.U.’s justice commissioner, used the occasion to declare manipulative interface design a practice to be stamped out. Germany went further and wrote a mandatory cancellation button into its civil code. Brussels, meanwhile, is preparing the Digital Fairness Act, scheduled for proposal in the last quarter of this year, after public consultations that began in July, 2025; it is meant to close the gaps that a 2024 review of E.U. consumer law identified, dark patterns in subscription and cancellation flows among them. The scale of the problem is not in dispute: a study commissioned by the E.U. in 2022 found that ninety-seven per cent of the most popular websites and apps deployed at least one dark pattern.
What makes the Polish case more than a local curiosity is the defendant. BOLD operates the same résumé builder under dozens of brands, Zety, LiveCareer, and MyPerfectResume among them, and, in August, 2025, it acquired the job boards CareerBuilder and Monster out of bankruptcy, with a winning bid of $28.4 million. In April of this year, a competitor called Rocket Resume sued the BOLD companies in federal court in California, alleging that a network of seemingly independent sites controls more than eighty per cent of the American résumé-builder market and misleads its customers; these are allegations, untested by any court, and BOLD has moved to dismiss the suit as deficient. What is documented is the pattern in the complaints American consumers file with the Better Business Bureau: an initial charge of $2.95, followed by monthly debits of $23.95. The arithmetic will sound familiar in Warsaw. As far as we can tell, the Polish decision is the first by a European consumer authority to call this model by name and to bill it to the operator directly.
Poland took a long road here. The prototype was a service called Pobieraczek, “the little downloader,” which in the early twenty-tens turned “free” file downloads into paid subscriptions; the fines survived judicial review. Closer to the present is Vinted: in 2022, the regulator fined the Lithuanian resale platform more than 5.3 million złoty over two disclosure practices, and in 2023 a court struck down one of them while upholding a 1.12-million-złoty penalty for the other. The lesson runs in both directions: the timing standard is enforced in Poland with real consistency, and it is reviewed by courts with real independence, which is the one serious field of play BOLD has left.
Strip away the statutes and the settlements, and the principle that regulators from Washington to Warsaw are converging on fits in a sentence: talk about money before the consumer’s work, not after. The InterviewMe decision is under appeal, and the courts may yet resize it. The button, meanwhile, is still there, still promising, in its cheerful imperative, “Download your CV.” The question now attached to it, on two continents, is what an hour of someone’s evening is allowed to cost.
The legal and factual position described here is current as of July 8, 2026. Decision RPZ 6/2025 of December 29, 2025, is under appeal before Poland’s Court of Competition and Consumer Protection and is not final. Accounts of foreign proceedings draw on primary materials from the F.T.C., the U.S. Department of Justice, and the European Commission, and on the Court of Justice of the E.U.’s judgment in Case C-565/22; allegations in pending lawsuits are identified as such.
Robert Nogacki – licensed legal counsel (radca prawny, WA-9026), Founder of Kancelaria Prawna Skarbiec.
There are lawyers who practice law. And there are those who deal with problems for which the law has no ready answer. For over twenty years, Kancelaria Skarbiec has worked at the intersection of tax law, corporate structures, and the deeply human reluctance to give the state more than the state is owed. We advise entrepreneurs from over a dozen countries – from those on the Forbes list to those whose bank account was just seized by the tax authority and who do not know what to do tomorrow morning.
One of the most frequently cited experts on tax law in Polish media – he writes for Rzeczpospolita, Dziennik Gazeta Prawna, and Parkiet not because it looks good on a résumé, but because certain things cannot be explained in a court filing and someone needs to say them out loud. Author of AI Decoding Satoshi Nakamoto: Artificial Intelligence on the Trail of Bitcoin’s Creator. Co-author of the award-winning book Bezpieczeństwo współczesnej firmy (Security of a Modern Company).
Kancelaria Skarbiec holds top positions in the tax law firm rankings of Dziennik Gazeta Prawna. Four-time winner of the European Medal, recipient of the title International Tax Planning Law Firm of the Year in Poland.
He specializes in tax disputes with fiscal authorities, international tax planning, crypto-asset regulation, and asset protection. Since 2006, he has led the WGI case – one of the longest-running criminal proceedings in the history of the Polish financial market – because there are things you do not leave half-done, even if they take two decades. He believes the law is too serious to be treated only seriously – and that the best legal advice is the kind that ensures the client never has to stand before a court.
