Poland has its own act on artificial intelligence systems, and that act points at EU regulation 2024/1689. A venue that runs a chatbot, a voice line or automated triage applies a ready-made system rather than supplying one, and the act reaches it because the system is used in business. The practical duties follow from that position.
This page does a narrow job for the owner of a restaurant, a bistro or a cafe in Poland: what the Polish act contains, which words it uses, which body it names, and what you can settle before launch instead of after a complaint. It does not classify your system by risk level and it does not print penalty amounts — both require tying a general rule to your particular case, and that tie is what we have not measured. A wrong legal figure reads more confidently than a right one.
Poland now has its own act on artificial intelligence systems
The act is the Ustawa z dnia 3 lipca 2026 r. o systemach sztucznej inteligencji, published in the Polish Journal of Laws as Dz.U. 2026 poz. 1003 (Dziennik Ustaw / ISAP, full text of the act, opened 28.08.2026). A national statute, not a guideline and not a vendor white paper. Wordings from it are rendered here in translation rather than quoted verbatim; the binding text is the Polish one behind that link, and it is where a lawyer will read it back to you.
The first thing worth knowing is what it is about, because the popular picture of an "AI law" is usually wrong. Article 1 lists five things the act determines: the organisation and manner of market surveillance over artificial intelligence systems and general-purpose models within the scope covered by regulation 2024/1689; proceedings in cases of infringement of that regulation and of the act; the conditions and procedure for accreditation and notification of conformity assessment bodies; supporting measures for the development of such systems; and the rules for imposing administrative financial penalties (Dz.U. 2026 poz. 1003, art. 1).
Four of those five describe machinery of the state: who supervises, how proceedings run, how bodies get notified, how money penalties are imposed. The act builds supervision and procedure. It is not a catalogue of sentences your bot may say. The substantive duties — what a system must do, what has to be disclosed, what documentation exists — live in the EU regulation to which the act refers, and this page does not retell them.
Artificial intelligence system — a term the Polish act does not define on its own. Article 4 point 1 says it means an AI system within the meaning of article 3 point 1 of regulation 2024/1689. The act borrows the meaning instead of writing a second one that would have drifted from the first within a year.
The act also lists matters it does not apply to at all: national defence and security, the special services, military counter-intelligence and intelligence, and scientific research in the part that does not include testing in real conditions (Dz.U. 2026 poz. 1003, art. 2 ust. 1). None of that touches a dining room, but it shows what kind of instrument you are holding: one written with large deployments in mind, which still reaches a fifty-seat bistro.
Where the Polish act points at EU regulation 2024/1689
The connection is printed in the definitions, not implied. Article 4 is a list of fifteen terms, and each is defined by a pointer built to one pattern, which in translation reads: within the meaning of article 3, point so-and-so, of regulation 2024/1689 — with the point number that belongs to that particular term.
| Word the Polish act uses | Where the act puts it | Where the meaning lives |
|---|---|---|
| artificial intelligence system | art. 4 point 1 | art. 3 point 1 of regulation 2024/1689 |
| risk | art. 4 point 2 | art. 3 point 2 of the regulation |
| provider | art. 4 point 3 | art. 3 point 3 of the regulation |
| operator | art. 4 point 4 | art. 3 point 8 of the regulation |
| market surveillance authority | art. 4 point 12 | art. 3 point 26 of the regulation |
All five rows are read from the act itself (Dz.U. 2026 poz. 1003, art. 4, opened 28.08.2026).
That gives you a reading habit worth hours. When you look for the meaning of a word, do not search the Polish text — search the article of the regulation the Polish text names. It also fixes the boundary of this page: where a duty comes from the regulation rather than from the statute, this page says so instead of inventing an article number for it.
Provider or operator: which word the act puts on your venue
Article 3 paragraph 1 says the act applies to the entities referred to in article 2 paragraph 1 of regulation 2024/1689, with one exclusion: natural persons, in the scope of the duties of entities applying the regulation, if they use an artificial intelligence system solely for personal purposes unconnected with business activity (Dz.U. 2026 poz. 1003, art. 3 ust. 1, opened 28.08.2026).
Turn that around and the answer is immediate. A chatbot that takes table requests, a voice line that answers the phone at seven in the evening, a script that sorts messages before a human sees them — all are used in connection with business activity. The exclusion does not cover you. That is read out of the act, not drawn by analogy from it, and the difference matters: analogy is how one careful sentence turns into three careless ones.
The act's vocabulary here is short. It names the provider and the operator, and in the register of penalised systems it names the operator the decision concerns. The exact content of each position lives in the regulation, so this page names the words rather than retelling the definitions.
Role in the chain — the position a business occupies relative to a system: the party that supplies it, or the party that puts it to work. The duties differ, and taking on someone else's position by mistake is the fastest way to spend a month producing documents nobody asked for.
| Position | Who that usually is around a venue | What follows in practice |
|---|---|---|
| Provider | the company whose product you licensed: the voice platform, the chat engine, the model behind them | technical documentation, conformity work and the declarations about the system as a product |
| Operator applying the system | the venue itself — the legal entity whose phone line and website the system answers on | how the system is used here, on what data, with what limits, and what happens when it fails |
| Neither | the waiter, the shift manager, the guest | none of the above, though the shift manager is who the handover lands on |
Why taking on the provider's position by mistake costs a month
An owner reads a summary written for vendors, assumes the strictest reading applies, and starts assembling a technical file for a product they did not build — while the thing that genuinely belongs to them stays unwritten, because it looked too simple to be the answer. The honest sequence is the reverse: settle what belongs to the party applying the system, put the rest into the supplier contract, and ask the supplier in writing for what they owe.
Three places where a machine already stands in a typical venue
Most owners answer "we do not use AI" and are wrong by three counts. The machine is rarely announced as artificial intelligence; it arrives as a feature of a booking tool, a widget on the site, or a setting in the phone system.
The voice line
Someone calls at the peak hour and a system answers: hours, a name, a time, sometimes a read-back. What such a line answers and what it must not try to answer is covered on the page about the AI reception line, and from the working side on the pillar about what a voice assistant answers on the phone.
The chat on the site
A window in the corner that answers about the menu, allergens, hours and parking — the most common first machine in a venue and the easiest to forget, because marketing installed it and nobody in operations owns it. What such an assistant does is described on the page about the chat assistant on the site; the difference between a scripted bot and an agent that acts is set out in the article on an AI agent versus a chatbot.
Automated triage of incoming messages
The quietest of the three: messages sorted, prioritised or answered with a template before a person opens them. Sorting by rules is covered on the page about rule-based handling of the incoming stream, and ranking of enquiries on the page about triage of enquiries. What can genuinely be handed to a system is the subject of the article on what can really be handed over.
| Place | What the guest should understand | Where the conversation goes when it fails |
|---|---|---|
| Voice line | that the answer is machine-made and can be checked with a person | to the shift phone, with the caller's number kept |
| Chat on the site | the same, plus which answers are authoritative | to a mailbox a person actually opens, or to a callback |
| Triage of messages | that a first reply may be automatic | to the manager's queue, marked unhandled rather than closed |
The right-hand column is the one owners skip and the one that decides whether this is a service or a trap. A path that ends nowhere is not a path.
A fourth place belongs here even though the guest is not in the conversation: a machine-written reply to a public review, which sits under this subject and under the separate rules covered on the page on reviews and what the law allows.
The guest has to know who is speaking
Say it plainly and early. This page attaches no article number of the Polish act to that sentence: the act does not contain such a duty, because it builds supervision and procedure, while the transparency duties sit in the EU regulation.
What the act does give you is a reason that needs no article number. Any person, legal entity or organisational unit without legal personality may lodge a complaint with the supervisory body; the complaint contains the name or description of the system it concerns and, where it can be established, the name and electronic delivery address of the entity concerned, and it is filed electronically (Dz.U. 2026 poz. 1003, art. 59 ust. 1-3, opened 28.08.2026).
Read that as an operator and the arithmetic is simple. A guest who felt deceived by a machine now has a named address to write to, and the complaint form asks for your name. Two sentences on your site and one at the start of a call remove the premise of the grievance. Two habits go with it: give the machine a name that does not impersonate a person, and disclose in the language of the conversation — a Polish line that discloses in English discloses to nobody.
Recording a conversation held by a machine: two separate rules over one action
Recording a call handled by a machine sits under two bodies of rules at once. One is the framework around artificial intelligence systems described here. The other is the ordinary law on personal data, which does not care whether the voice was human. One action, two sets of conditions, and satisfying one tells you nothing about the other. The second set has its own pillar: consent to contact and the recording of conversations are handled on the page about marketing consent and call recording, and where the data physically ends up when you automate is the subject of the article on automation and data protection.
One thing this page will not give you is a retention period for recordings. We looked for it in the acts and did not find it. Settle it with your data protection adviser and write it down where the shift manager can see it, together with who may listen to a recording and on what occasion.
What to fix before launch: purpose, limits, behaviour on failure
Three short documents do more than any amount of reading, and none needs a lawyer to start.
Purpose written in one sentence
"This system answers calls about opening hours and takes booking requests between eighteen and twenty-two." That is a purpose. "Improving guest experience with AI" is not — it cannot be checked, so it cannot be breached, so it protects nobody. If the sentence runs past two lines, you have two systems and should write two sentences.
The list of things the machine must not do
Write the prohibitions before the capabilities, because prohibitions are what you will be asked about. It must not confirm a table it cannot hold. It must not state a price it does not have. It must not answer about allergens beyond the list it was given. It must not claim to be a person. It must not promise a callback nobody is on the hook for. Five lines like these beat a forty-page policy, because a shift manager will read five lines.
What happens when the machine does not know
The common failure is not a wrong answer; it is a confident answer to a question outside the system's list. Decide in advance what the machine says when it does not know, and make that sentence end in an action: a transfer, a callback, a message landing in a queue with an owner. The article on the five situations where we advise against automating is largely a list of cases where this step was skipped.
There is also a formal route for genuine uncertainty, and it is not expensive. The supervisory body may issue individual opinions and explanations in matters within its scope, and a request may be filed by an entity obliged to apply the regulation and the act, or by one that only plans to take up activity that would bring it within their scope — exactly the position of a venue considering a voice line. The request describes the factual situation or the future event and states the applicant's own legal position; the fee is 150 zł. The opinion is issued no later than 30 days from filing, or 60 days in particularly complicated cases; failure to issue it within those periods counts as an opinion agreeing with the position the applicant stated, and the opinion binds the body in that case (Dz.U. 2026 poz. 1003, art. 8 ust. 1, art. 9 ust. 1, art. 11 ust. 1, art. 12 ust. 1 and ust. 3, art. 13 ust. 1, opened 28.08.2026). Issued opinions are published after anonymisation.
Handover to a person: when it has to happen and how you measure it
Handover to a person — the mechanism by which a conversation leaves the machine and reaches a member of staff. It exists if it can be invoked and if there is somebody to receive it. Without a receiver it is a sign on a door, not a door.
This is the part owners believe is working and almost never measure. Both figures below come from your own call and chat logs; no industry benchmark is quoted, because there is no official publication of one.
Handover completion rate = Conversations that reached a member of staff after handover was invoked ÷ Conversations in which handover was invoked
Conversations that reached a member of staff after handover was invoked— conversations in which a person actually spoke or replied, counted in conversations;Conversations in which handover was invoked— conversations in which the guest or the system triggered the handover, counted in conversations;- the result is a dimensionless share between 0 and 1.
The denominator is the trap. Put all conversations in it and a venue whose handover is completely broken still shows a fine-looking figure, because most conversations never needed a person. A worked example: over one week the log shows 84 conversations in which handover was invoked, and in 61 of them a member of staff spoke or replied. 61 ÷ 84 = 0.726, so seven invocations in ten completed and 23 guests were left holding a promise. Check in reverse: 0.726 × 84 = 61.0 conversations, which matches the count.
Time to a person = Timestamp of the staff reply − Timestamp of the handover invocation
Timestamp of the handover invocation— the moment the system or the guest triggered the handover;Timestamp of the staff reply— the moment a person first spoke or wrote;- the result is a duration, reported as a share of conversations that fit inside your own threshold, not as an average.
Averages hide the tail, and the tail is the guest you lost. Ten handovers answered in twenty seconds and one abandoned entirely produce a comfortable mean and one person who will never come back. Set a threshold you are willing to defend out loud — for a phone line at the peak hour, usually well under a minute — then read the ones that missed it, one by one.
Where such figures live is covered on the page about triage and the numbers behind it and on the pillar about an AI-assisted management system for a restaurant; what happens to an enquiry after the first conversation, in the article on follow-up automation and on the page about following up an enquiry.
Supervision: the body the act names, and the public list it keeps
The act names one body. The Komisja Rozwoju i Bezpieczeństwa Sztucznej Inteligencji — the Commission for the Development and Safety of Artificial Intelligence — is the market surveillance authority for artificial intelligence systems, and it also acts as the single point of contact (Dz.U. 2026 poz. 1003, art. 5 ust. 1 and ust. 2, opened 28.08.2026). Its tasks are listed separately: supervising compliance with the regulation and the act, issuing decisions in infringement cases, exercising the competences of a market surveillance authority, education and information work, exchanging information with the authorities of other member states, and keeping the register of complaints (Dz.U. 2026 poz. 1003, art. 6).
Four features of how it works deserve an owner's attention, and none needs a penalty figure to be useful.
Inspections are a defined procedure, not a surprise visit. An inspection begins on the body's own initiative, at the request of its chair, deputy chair or a member, or at the request of a national authority or public entity; it is carried out no earlier than seven days after the notice of commencement has been delivered, and remotely by default (Dz.U. 2026 poz. 1003, art. 48 ust. 1, art. 49 ust. 1-3). A remote inspection with a week's notice is a document exercise — which means the documents from the previous section are the whole preparation.
The penalised systems are published, and the entry names the operator. The body publishes in the Public Information Bulletin a list of artificial intelligence systems in respect of which a penalty decision has been issued. The entry contains the name of the system and of the operator the decision concerns, a description of how the system works with an indication of the provisions at issue, information about decisions concerning the same operator taken by authorities of other member states, and a reference to the decision (Dz.U. 2026 poz. 1003, art. 66 ust. 2-3, opened 28.08.2026). For a restaurant this is the sharpest line in the act, and it has nothing to do with money: the name over your door can end up on a public list, searchable, next to a description of what your system did.
There is a court at the end of the road, and it is a specialised one. An appeal against a decision of the body lies to the Sąd Okręgowy w Warszawie, sitting as the court for competition and consumer protection, filed through the body itself; lodging it suspends enforcement of the decision as regards the administrative financial penalty (Dz.U. 2026 poz. 1003, art. 65 ust. 2 and art. 67). The act builds the procedure for these cases into the Code of Civil Procedure, adding a dedicated division on proceedings in artificial intelligence matters (Dz.U. 2026 poz. 1003, art. 115).
Case files are kept for ten years from delivery of the decision, unless separate provisions set a different period (Dz.U. 2026 poz. 1003, art. 69). Note what that number is and is not: it is the retention period for the authority's case files, and it says nothing about how long you keep call recordings.
Financial penalties exist in the act, and what that changes in the price of carelessness
Administrative financial penalty — a money sanction imposed by the supervisory body for infringement of the regulation or the act. The rules for imposing such penalties are one of the five things the act determines, and it contains articles on the decision that imposes them, on what an appeal does to their enforcement, and on the route to a negotiated reduction (Dz.U. 2026 poz. 1003, art. 1 point 5, art. 62, art. 67, art. 70, opened 28.08.2026).
This page does not print the amounts, and the reason is a rule rather than caution. A penalty figure means something only once it is attached to a category of infringement and to a particular system in a particular role — and that attachment is what we have not measured. A sum quoted without it looks authoritative, gets copied, and is wrong for almost every reader who copies it. Take the figure for your own case from the text of the act with your legal adviser.
The shape of the exposure is knowable without a single number:
- the decision on infringement comes from the supervisory body, not from a court, and the court stage comes afterwards;
- an appeal suspends enforcement of the money part, so the timeline is longer than a single letter suggests;
- there is a settlement route: the body may open the possibility of an agreement on the terms of an extraordinary mitigation of the sanction, which requires the party to bring forward the circumstances of the infringement and the evidence for them;
- and running alongside all of it is the public list from the previous section, which no appeal removes from a search engine's memory.
So the change in the price of carelessness is mostly not the fine. It is that an unlabelled machine, a handover that goes nowhere and a recording nobody can explain now have an address to be complained to, a procedure to be examined in, and a page to be published on.
A launch order for a machine on the line that you will not have to redo
Sequence matters: half of these steps are cheap before launch and expensive after.
- Name the position. One line: you apply a ready-made system, and this is who supplies it, with their full legal name and the product name.
- Write the purpose and the prohibitions as described above, in the language your shift managers speak, and post them where those people work.
- Decide the disclosure. The exact sentence at the start of a call and on the chat window, in the language of the conversation.
- Build the handover before the greeting. Who receives it, on which device, during which hours, and what happens outside them. A handover to an unattended mailbox is worse than none: it spends the guest's patience before failing.
- Settle the recording question separately, and write down the retention period and who may listen.
- Ask the supplier in writing what the system does, on what data, what it does when it does not know, and what they undertake in their own position.
- Turn the two measurements on from day one — completion rate and time to a person, reviewed weekly for the first month.
- If your case is genuinely unusual, use the individual opinion route rather than guessing, and do it before launch, while the request can still describe a future event.
- Re-read the act when it changes. It is new, and new acts move.
Two things not to do. Do not copy another venue's policy: the position, the supplier and the purposes differ, and a borrowed document describes somebody else's system. And do not let the person who installed the widget be the only one who knows it exists. Which processes are worth handing over at all is set out on the pillar about what an AI-assisted management system covers; if this is the first legal question you have ever put in writing about your venue, start one step earlier, with approval of the premises and HACCP.
Frequently asked questions
Does Poland have its own law on artificial intelligence?
Yes. The Ustawa z dnia 3 lipca 2026 r. o systemach sztucznej inteligencji was published in the Journal of Laws as Dz.U. 2026 poz. 1003. It determines how market surveillance over artificial intelligence systems is organised, how infringement proceedings run, how conformity assessment bodies are accredited, what supports development, and the rules for imposing financial penalties.
How does it relate to the EU AI regulation?
By direct reference. The act's definitions are pointers: system, risk, provider, operator and market surveillance authority are each defined as having the meaning given in a named article of regulation 2024/1689. The Polish text carries the procedure and the supervision; the substance of the terms is taken from the regulation rather than restated.
Is a restaurant a provider or an operator of an AI system?
A venue almost always applies a system somebody else supplies, so it is not in the supplier's position. The act names both positions and defines each by reference to the regulation. What it says directly is that the exclusion for natural persons using a system solely for personal purposes unconnected with business activity does not cover a venue.
Must a guest be told they are talking to a machine?
Say so, plainly and at the start. The transparency duties sit in the EU regulation rather than in the Polish act, so this page attaches no Polish article number to that sentence. The act supplies a separate, very practical reason: any person may complain to the supervisory body about a system, naming the entity concerned, and a clear label removes the premise of that complaint.
Does recording an AI call need a separate basis?
Treat it as a separate matter: it is governed by the ordinary rules on personal data, not by the artificial intelligence act, and satisfying one set says nothing about the other. The retention period is not stated in either act, so settle it with your data protection adviser rather than adopting a number found in an article.
What has to exist before a voice line goes live?
Four things in writing and one that works: the position you occupy and who supplies the system; the purpose in one checkable sentence; the list of things the machine must not do; the exact disclosure sentence; and a handover with a named receiver on a named device during named hours. If your set-up is unusual, the individual opinion route exists precisely for a future event and costs 150 zloty, with a thirty-day deadline.
Are there financial penalties in the Polish act?
Yes. Setting the rules for imposing them is one of the five things the act determines, and it carries the articles on the infringement decision, on the suspension of enforcement when an appeal is lodged, and on the settlement route to an extraordinary mitigation. This page deliberately does not print the amounts: a figure means nothing until it is attached to a category of infringement and to a particular system, and that attachment has not been measured here.
Take the shortest step first: call your own line at the peak hour, ask for a person, and time what happens. A message that says "connecting you to an operator" with nobody at the other end is not a mechanism. The rest of the restaurant material is collected in the restaurant section.