KNF Playbook
Pre-inspection AI governance preparation for Polish financial institutions.
The problem
"KNF named AI in their 2026 supervisory priorities. Zero Polish banks have published AI governance frameworks."
Problem 1
The inspection infrastructure is live
KNF deployed its own AI-based supervisory system in 2025. The enforcement mechanism exists before bank compliance infrastructure does. When KNF arrives, they know what to look for.
Problem 2
EBA guidance arrives after the window
EBA operational guidance for AI governance is expected in 2027 — after the August 2026 EU AI Act enforcement deadline. Polish banks must act before the official playbook exists.
Problem 3
72 hours to produce evidence
A serious AI incident requires documented evidence of appropriate risk management within regulatory response windows. If the documentation doesn't exist before the incident, it cannot be created retroactively.
Method
Four phases. One inspection-ready package.
Regulatory mapping
Map KNF 2026 supervisory priorities against current documentation. Cross-reference with BaFin's January 2026 guidance template — the model KNF will follow. Identify critical compliance gaps.
Documentation build
AI System Register in inspection-ready format. Article 14 human oversight evidence file. Article 26(5–6) incident response and suspension procedure documentation. Log retention evidence.
Package assembly
Compile the full inspection-ready documentation package. Validate each element against the BaFin template. Gap closure evidence file built alongside the package.
Inspection readiness briefing
Briefing session with CRO and Compliance team: what KNF examiners look for, how to present documentation, what not to say. Optional: mock examination session (examiner-style Q&A).
What you get
Inspection-ready package.
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AI System Register
Inspection-ready format, Article 26 compliant, structured to answer the questions a KNF examiner will ask.
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Article 26 compliance documentation package
All 13 deployer obligations evidenced — oversight designation, log retention, incident procedures, DPIA trigger analysis.
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KNF inspection readiness briefing deck
What examiners look for. How to present. Mapped to KNF 2026 supervisory priorities.
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Gap closure evidence file
Documents the delta between starting state and final documentation package. Demonstrates proactive compliance action.
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Optional: Mock examination session
Examiner-style Q&A with CRO and Compliance team. Stress-test the documentation package before the real inspection.
Who it's for
The inspection readiness owner.
Owns inspection readiness. Responsible for the documentation package KNF will ask to review.
Owns KNF relationship. Needs to know what examiners look for before they arrive.
Coordinates the KNF response. Needs a structured programme, not a crash course.
Proactive window
The proactive window closes mid-2026.
KNF inspections are announced 2–4 weeks in advance. That is not enough time to build documentation from scratch. August 2026 remains the legally binding deadline — the proposed Digital Omnibus amendment has not been adopted. Institutions that prepare now are protected either way.
What comes next
KNF Playbook opens the door.
Readiness Sprint
→The cross-sector Article 26 compliance programme that underpins the KNF Playbook. For institutions that need the full governance framework, not just the KNF-specific layer.
Advisory Retainer
Quarterly documentation updates as KNF guidance evolves and regulation develops. Keep your inspection package current.
AI Risk Model
→Your organisation's AI risks ranked and explained. The natural input to any governance framework build.
Is your AI governance documentation inspection-ready?
Every engagement starts with a short conversation. No commitment, just specifics.
Let's talk →