The first provisions of the EU AI Act are already in force and directly affect companies using artificial intelligence systems. The initial focus is on prohibited AI practices and the obligation to ensure AI literacy among staff and relevant users. For companies operating in Poland, this means organising how AI is used across business, HR, compliance and IT.
The AI Act is an EU regulation, so it applies directly across Member States. The Polish Ministry of Digital Affairs indicated that the first provisions started to apply from 2 February 2025, including prohibited practices and AI literacy requirements.
The prohibited-practices rules target AI systems considered particularly dangerous. These may include uses that infringe fundamental rights, manipulate behaviour or lead to unacceptable discrimination. Breaches can result in significant administrative fines.
AI literacy means that providers and deployers of AI systems should ensure that people working with AI have sufficient knowledge and skills. This is not only technical training. It should also cover risk awareness, limitations of AI tools, responsible use and understanding of how AI may affect business decisions.
For companies using AI in document analysis, customer service, HR, marketing or compliance, the practical response is to build a simple AI governance model: tool inventory, risk assessment, internal usage rules and training evidence.
The topic remains important in 2026 because further AI Act obligations apply in stages. Companies that use the current obligations as a starting point will be better prepared for future requirements concerning high-risk systems, documentation, oversight and supplier management.
What this means for our clients
- Identify where AI systems are used, including generative AI and AI features embedded in business applications.
- Check whether any AI use may fall into prohibited or higher-risk categories.
- Implement a basic AI literacy programme: training, usage rules, user responsibility and risk escalation.
- Define AI governance: process owner, tool register, supplier controls and decision documentation.
- Prepare a roadmap for the next AI Act stages, especially for AI used in HR, client assessment, compliance or risk analysis.
The AI Act is no longer a distant regulatory project – the first obligations already apply. We can support with a pragmatic readiness review covering inventory, risk, AI policy and training.
IT, Compliance, HR, Governance
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