What happened
On 28 October, Articles 8–18 of Poland's Act on Artificial Intelligence Systems (Journal of Laws 2026, item 1003) took effect. The same day, the Commission for the Development and Safety of Artificial Intelligence (KRiBSI), Poland's AI market supervisor, held its first meeting, chaired by Pamela Krzypkowska. Since then anyone can file a complaint about an AI system with the commission, and its website already offers electronic forms for applications and complaints.
For companies, the most important new mechanism is the individual opinion. It works like this:
- A company may apply if it is already subject to the AI Act, or if it plans an activity that will bring it under the Act. The request may cover an existing set of facts or a future event, which includes a deployment that does not exist yet.
- One request covers one issue. It must describe the situation exhaustively and set out the applicant's own position on its legal assessment. A bare question is not enough.
- The fee is PLN 150. The commission has 30 days to respond, or 60 in particularly complex cases.
- If the commission misses the deadline, it is deemed to have issued an opinion matching the applicant's position, and the fee is refunded in full.
- The opinion binds KRiBSI and any other authorities the commission consulted, but only for the facts described in the request.
- The same company may file its next request no earlier than 30 days after the previous one. An earlier request is left unexamined.
- The commission may later amend or revoke an opinion, for example after new European Commission guidelines. A company that followed the opinion before the change cannot be harmed by it.
- Opinions are published in the commission's Public Information Bulletin, anonymised and with trade secrets removed.
Our read
This is our interpretation. In July we wrote about the gap between obligations and supervision: the AI Act had applied since August, and there was still no authority to ask about it. That gap has closed. The authority now has two channels: complaints, which your customer or a competitor can file, and opinions, which you can request yourself.
A PLN 150 opinion is the cheapest legal certainty on the AI Act available in Poland today. It protects exactly what you described in the request, though. If you describe the system the way your sales deck does and it runs differently, the opinion covers a system you don't have. So the value of the request lies in the description of the facts. It has to say what data the system processes, who makes the decision and where the human is. That description should be written by someone who knows the system from the inside.
The second point is easy to miss: the 30-day limit applies to the company, not the team. A large organisation where five departments each have one AI Act question can file one request a month. Someone has to decide which question goes first. Otherwise the team that sends the form first wins.
The third point is the authority's silence. Speculation: the commission is only now recruiting its first staff, so deadlines may be tight in the first months. If the commission misses one, your position becomes the opinion. Write it as if it will be issued without edits, because it may be.
Why it matters
Private Equity
The 30-day limit applies to a single company, so each portfolio company has its own. In due diligence on a company that sells AI for recruitment, credit scoring or other Annex III uses, ask whether it holds an individual opinion on its classification. If it doesn't and the case is borderline, a request is a cheap way to close the risk before the next round or an exit. An opinion that binds the regulator is easier to show a buyer than a law-firm memo.
Enterprise
Decide who in the company runs the queue of questions to KRiBSI. Ideally that is the same person who keeps the register of AI systems. Collect the open questions from the business units, pick the one that blocks the most expensive decision, and only then file it. Remember that the opinion will be published. It will be anonymised, but the description of your system becomes part of a public body of interpretations that others will use.
SMB / mid-market
The fee is symbolic; the system description is not. If you use an off-the-shelf tool, first check whether the vendor has already requested an opinion. If you build your own, or modify someone else's tool and sell it under your name, an opinion before deployment costs less than a rebuild after a complaint. When we prepare such requests in our services, we start by writing down what the system actually does with data and where a human decides. Only then do we draft the position.
One move for this week
List the AI Act questions nobody in your company can answer with confidence today. Next to each, note which decision it blocks. Pick one and write two paragraphs for it: how the system really works, and how you think it should be assessed. If both paragraphs hold up after that exercise, you have a ready request, and the form is on the KRiBSI website. Describe your case: mailto:[email protected]?subject=Rozmowa%20z%20Aurora%20AI