Bilateral retinopathy of pancreatitis developed in a 36-year-old male patient during recurrent acute necrotizing pancreatitis. The retinopathy remained clinically unchanged between the detection and the death 6 days later. Characteristics of the retinal lesions were histologically similar to cotton-wool spots of other origin, but all the retinal vessels including vessels around and in the cotton-wool spots were intact and contained plasma and red blood cells. Absence of vascular occlusion and endothelial damage suggests that in acute pancreatitis vascular embolisation in the retina is not necessary to the development of cotton-wool patches.