Poland’s AI Act Enforcement Law: Supervision, Inspections and Penalties

On 24 July 2026, the President of the Republic of Poland signed the Polish law ensuring the application of the EU AI Act. The new legislation establishes a national supervisory framework for the artificial intelligence market, creates the Commission for the Development and Safety of Artificial Intelligence, and introduces inspections, sanctions and regulatory sandboxes for businesses developing or deploying AI systems. Find out what obligations arise from the new rules, when they will apply and what risks businesses should prepare for.

What Does Poland’s AI Act Enforcement Law Change?

The aim of the Act is to ensure the effective application and enforcement of EU artificial intelligence rules in the Polish market. The main change is the creation of a new, specialized supervisory body – the Commission for the Development and Safety of Artificial Intelligence (the Commission). A key development for businesses is also the introduction of regulatory sandboxes into the Polish legal system, enabling companies to safely test innovative AI systems under the supervisor’s eye before launching them on the market.

Commission for the Development and Safety of Artificial Intelligence: Poland’s New AI Supervisory Authority

The establishment of the Commission is one of the most important elements of the new Polish law ensuring the application of the EU AI Act. As a new central supervisory authority, the Commission gains broad investigative and decision-making powers that will directly impact business operations.

What Powers Does the Commission for the Development and Safety of Artificial Intelligence Have?

The Commission is not merely an advisory body – it is a significant authority equipped with tools to actively shape the market. Its key competencies include:

• conducting audits and imposing fines on businesses;
• issuing warnings, corrective decisions, and orders to block system access to users or withdraw a system from the market entirely – if an AI system is deemed to violate the law;
• issuing binding individual opinions at the request of a business planning an AI deployment (application fee is PLN 150), which provides legal certainty before investing in new technologies as it is binding on state authorities;
• maintaining a public register listing AI systems against which penalty decisions have been issued.

Duty to Cooperate with the Commission During Inspections

In the event of an inspection, businesses have an unconditional duty to cooperate with the authority, which in practice means providing full access to documents, IT systems, and cloud data. Failure to cooperate (obstructing or preventing inspection activities) carries administrative sanctions and may also result in direct criminal liability – punishable by fines or even restriction of liberty.

AI Regulatory Sandboxes in Poland: Safe Testing of AI Systems

The new Act on Artificial Intelligence Systems introduces regulatory sandboxes into the Polish legal order. This is a special, controlled environment allowing businesses to safely test innovative AI technologies under the supervision of the new regulatory body before releasing them to the broader market. In line with EU requirements, every EU member state, including Poland, must launch at least one such regulatory sandbox by August 2, 2026.

What Does Participation in an AI Regulatory Sandbox Offer Businesses?

By participating in a sandbox, businesses receive support in adapting their systems to the rigorous requirements of the EU AI Act. The main benefit is the possibility of obtaining exemptions from certain technical and procedural requirements for the duration of pilot projects. The duration of sandbox tests ranges from 6 to 12 months.

Upon completing the program, the company receives a final report and confirmation of participation. Crucially for legal certainty, within 90 days after finishing the test period, the participant can apply to the Commission for a binding individual opinion regarding their AI system, which the Commission must issue within 14 days.

Who Can Join an AI Regulatory Sandbox and How Much Does It Cost?

The Act provides highly favorable conditions for smaller enterprises to stimulate market innovation:

• For micro, small, and medium-sized enterprises (SMEs), participation is completely free.
• For local government units, the fee will not exceed twice the minimum monthly wage.
• For large enterprises, the fee will cap at four times the minimum monthly wage.

The selection of projects for the sandbox will take place through a transparent competition organized by the Commission. Offers will be evaluated by a specialized competition team, with preference given to EU-based entities. If an application is rejected, businesses have the right to appeal within 7 days.

Appeals Against Commission Decisions Before the Court of Competition and Consumer Protection

Additionally, to ensure effective judicial review of supervision, the Act introduces separate provisions into civil procedure, under which appeals against decisions and rulings of the new Commission will be heard directly by the specialized Regional Court in Warsaw – the Court of Competition and Consumer Protection (SOKiK).

What Duties Do Businesses Have in an AI Regulatory Sandbox?

Testing in a safe environment does not mean a lack of control. Businesses admitted to the program must:

• inform users and other affected entities about their participation in the regulatory sandbox and the terms of that participation;
• submit an annual progress report to the Commission;
• publish information on their website regarding participation in the regulatory sandbox and eligibility conditions;
• promptly notify the Commission of any changes in legal or factual circumstances related to the participating project.

It should be remembered that the Commission retains the right to inspect participants. If it detects non-compliance with the conditions, the company will be given at least 30 days to remedy the situation. Ignoring the request risks exclusion from the sandbox.

Polish AI Act: Key Deadlines for Businesses

The Act was published on July 27, 2026 and enters into force in stages, giving companies time to adapt to the new regulations. Below is the schedule of key dates from a business perspective:

• July 28, 2026 – organizational procedures launch to enable the appointment of the new Commission, and most provisions of the Act enter into force under general rules.
• August 2, 2026 – the deadline under the EU schedule for launching regulatory sandboxes and applying a significant portion of the substantive provisions of the AI Act.
• October 28, 2026 – strict rules on conducting inspections, imposing administrative fines, and criminal sanctions come into force. From this date, companies will also be able to apply to the Commission for binding individual opinions.

Prepare Your Business for the Polish AI Act and the EU AI Act

The entry into force of the new Act and the EU AI Act requires businesses to swiftly adjust their processes, systems, and documentation. A lack of proper preparation risks not only heavy financial penalties, but also the suspension of technology projects. At the same time, because these regulations are brand new and the decision-making practice of the newly established Commission is yet to develop, flexible and rapid adaptation is crucial – before the first inspections and interpretative uncertainties arise.

Our law firm offers a wide range of services related to artificial intelligence regulations. We conduct comprehensive compliance audits and AI system classifications, produce documentation for operators of high-risk systems in accordance with the applicable standards, assist in implementing a detailed labelling plan, as well as we assist in drafting internal policies and procedures for the safe use of technology, and deliver dedicated training for executive management, legal teams, and IT departments.

We also provide comprehensive support tailored to the new Polish legislation. We can effectively assist your business in joining the regulatory sandbox, in obtaining binding individual opinions from the Commission, and representing your company in proceedings and inspections before the new regulatory authority – including procedures aimed at mitigating potential fines and before the Court of Competition and Consumer Protection, which hears appeals against decisions.

Do you have questions about the new regulations or plan to deploy AI-based tools?
Contact our team – we will help you safely navigate your business through the upcoming changes.