Germany’s BaFin will monitor the use of artificial intelligence by banks and insurers. Among other things, the regulator will examine chatbots, credit scoring systems and algorithms used to calculate insurance risk. The aim is to reduce discrimination, increase transparency and ensure that automated decisions do not deprive customers of fair access to services.
Will similar controls be introduced in Poland? It is possible, but the institutional model will be different. The Act on Artificial Intelligence Systems was promulgated on 27 July 2026. It establishes the Commission for the Development and Safety of Artificial Intelligence, which will oversee the market, receive complaints and respond to unlawful uses of AI. Its membership will also include a representative from the Financial Supervision Authority. The main provisions of the Act will come into force on 11 August, whilst some of the regulations concerning the supervisory framework will come into force on 28 October 2026.
Poland is therefore not copying the German model one-to-one. In Germany, a strong role is assigned to the sector-specific financial regulator. In Poland, supervision is to be more decentralised, with a central commission cooperating, amongst others, with the Financial Supervision Authority (KNF).
For Polish banks, insurers and fintech firms, this means they will have to document the operation of algorithms more thoroughly, monitor data and ensure human oversight. The most demanding obligations concerning high-risk systems, including credit assessment, are set to come into force from December 2027.
The German case is worth monitoring, as it will show whether stricter supervision curbs innovation or, on the contrary, increases customer confidence and facilitates the safe implementation of AI. For Polish institutions, one key takeaway is that the automation of financial decisions is becoming a legal, business and reputational issue.
