04 / Expertise

EU AI Act compliance for companies outside the EU

If your AI system or model reaches users in the EU, the AI Act applies to you, wherever your company is based. We classify your system, prepare the complete set of documents and stand next to you before the Polish authority.

Who this is for

  • Non-EU providers of AI systems and general-purpose AI models with users in the EU.
  • Companies deploying AI in Poland: HR, customer service, finance, health.
  • Software vendors whose EU clients ask for AI Act clauses and documentation.

What we do

01 · Role and risk classification

Provider, deployer, importer or distributor; prohibited practice, high-risk, transparency-only or minimal risk. In writing, with the reasoning, because authorities will ask for it.

02 · Complete documentation package

Everything the AI Act expects to exist before the product reaches the EU market: technical documentation (Annex IV or XI), risk management and data governance records, instructions for use, human-oversight procedures, transparency notices under Article 50, AI literacy policy, internal AI use policy, incident procedure, registration data. Delivered as a set of documents you can hand to an authority, a customer or an authorised representative.

03 · Mandate and contracts

Drafting the written mandate for your EU authorised representative under Articles 22 and 54 and helping you choose one; AI clauses in customer and supplier contracts; allocation of roles between provider and deployer (Article 25); data protection impact assessment where personal data is involved.

04 · Polish authority and disputes

Proceedings before KRiBSI, responses to information requests, and appeals to the Court of Competition and Consumer Protection in Warsaw.

What applies when

ObligationFrom
Prohibited practices (Art. 5), AI literacy (Art. 4)2 February 2025
General-purpose AI models, penalties, authorities2 August 2025
Transparency obligations (Art. 50)2 August 2026
High-risk systems listed in Annex III2 December 2027
High-risk AI in products under Annex I2 August 2028

Experience

  • Dr Tomasz Gulla chairs the Commission on Artificial Intelligence and Digitalisation of the Koszalin Bar Council, sits on the Commission on Digitalisation of the Polish Bar Council (Naczelna Rada Adwokacka) and advises the legal profession on the use of AI.
  • The firm works daily with the AI Act (consolidated text after the 2026 amendments), the Polish Act of 3 July 2026 on AI systems and the GDPR, and maintains its own document packages for AI compliance: classification reports, transparency notices, AI literacy and internal use policies, contract clauses.
  • We build and run AI tools in our own practice, so we know what the documentation must describe and what a regulator will ask about.

Fees

Fixed-fee classification report; documentation packages by fixed fee, scoped after the classification; proceedings before the authority by fixed fee or hourly rate. We quote before we start.

Questions, answered.

Does the AI Act apply to a company outside the EU?

Yes, when you place an AI system or a general-purpose AI model on the EU market, or when its output is used in the EU. The decisive question is your role: provider, deployer, importer or distributor.

When do I need an authorised representative in the EU?

A provider established outside the EU must appoint, by written mandate, an authorised representative in the Union before making a high-risk AI system available on the EU market (Article 22 AI Act) and before placing a general-purpose AI model on the EU market (Article 54 AI Act). We do not act as the representative ourselves; we draft the mandate, prepare the documentation the representative must verify and keep, and help you choose a representative.

Which obligations already apply?

Prohibited practices and AI literacy (Articles 5 and 4) since 2 February 2025; rules for general-purpose AI models and penalties since 2 August 2025; transparency obligations of Article 50 since 2 August 2026. The full high-risk regime for Annex III systems applies from 2 December 2027, and for AI in products covered by Annex I from 2 August 2028 (Article 113, as amended in 2026).

Who supervises AI in Poland?

The Commission for the Development and Security of Artificial Intelligence (KRiBSI), established by the Polish Act of 3 July 2026 on artificial intelligence systems, is the market surveillance authority and the single point of contact.

How high are the fines?

Under Article 99 AI Act: up to EUR 35 million or 7% of worldwide annual turnover for prohibited practices, up to EUR 15 million or 3% for other infringements, and up to EUR 7.5 million or 1% for supplying incorrect or misleading information to authorities.

Related insights

Your next step

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office@gulla.pl ↗+48 501 794 580

Gdynia & Słupsk, Poland

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