Poland - AI Development Strategy

Overview

The "Memorandum for the Development of Artificial Intelligence in Poland" is an inter‑ministerial declaration signed on 26 February 2019 that sets out Poland's coordinated approach to building a national AI ecosystem. It is a strategic (non‑binding) framework committing signatory ministries to cooperate on the creation of a national AI policy and ecosystem, public consultations, research and training initiatives, and alignment with international standards. The Polish government presents the memorandum as the foundation for the later publication and consultation of the "Polityka Rozwoju Sztucznej Inteligencji w Polsce na lata 2019–2027" (AI Development Policy 2019–2027). Official information and materials relating to the memorandum and subsequent policy work are available on the government AI portal and ministry pages such as the Ministry of Digitization's AI portal (see Droga Polski do AI) and the Ministry of Digitization consultation page (see Consultations: AI Development Policy 2019–2027).

Definitions

In the context of the memorandum, "artificial intelligence" is taken as a horizontal, transformative set of technologies and practices (machine learning, data analytics, automation, etc.) with cross‑sectoral impact. The memorandum frames "ecosystem" as the interconnected public, private and academic actors, data infrastructures and funding instruments needed to develop, deploy and govern AI in Poland. It distinguishes policy objectives from legally binding obligations: the memorandum is declaratory and programmatic, intending to coordinate ministerial actions, not to impose sanctions. Where useful, the subsequent policy document defined priority domains (education, research, public administration, industry) and timelines for implementation and consultation.

Governance and Institutional Framework

The memorandum mandates an inter‑ministerial coordination model: signatory ministries agreed to establish working groups, share data and expertise, pool strategic planning and prepare a national AI policy. The main coordinating role was assigned to the Ministry of Digitization (now hosted on the gov.pl AI hub) which led the policy drafting and public consultation process. The framework foresees engagement of academic institutions (Ministerstwo Nauki i Szkolnictwa Wyższego), economic and industrial policy departments (Ministerstwo Przedsiębiorczości i Technologii / Ministerstwo Rozwoju i Technologii), and investment policy units (Ministerstwo Inwestycji i Rozwoju). The memorandum also envisages regular reporting and monitoring by a central coordination entity and creation of dedicated expert teams to advise on ethics, standards, funding and GovTech procurement; see the published consultation materials at the Ministry page (see Consultation announcement). The structure aligns national coordination with EU and OECD actors to ensure interoperability and uptake of international recommendations.

Key Focus Areas

The memorandum and follow‑on policy work concentrate on several mutually reinforcing focus areas: (1) Skills and education — upskilling citizens and creating curricula for data science and AI across education levels; (2) Research and innovation — supporting interdisciplinary AI R&D, centers of excellence and public‑private research partnerships; (3) Data access and openness — enabling lawful reuse of public sector data while protecting privacy and sensitive information; (4) Public sector adoption (GovTech) — accelerating safe, ethical pilot projects in administration; (5) Business support — financing instruments, incubators and measures for SMEs and startups to adopt and provide AI solutions; (6) Ethics and fundamental rights — embedding human‑centric, trustworthy AI principles consistent with EU guidelines; (7) International cooperation — ensuring Poland participates in EU and OECD fora and aligns its rules with European standards. These themes are reflected in the publicly available policy draft and consultation materials (document and attachments available via the ministry's consultation page — see Policy document (attachment)).

Implementation Framework

Implementation is programmatic: the memorandum commits ministries to prepare a detailed national policy and to create implementation instruments such as coordinated funding calls, institutional support (centers, labs), and pilot programs in the public sector. The approach leverages existing public funding channels, EU funds and national research grants; it recommends setting up monitoring and co‑funding mechanisms to direct investment to priority areas. Implementation was sequenced through public consultations (August–September 2019), expert group formation, and eventual government adoption steps reported in ministry releases (see the Ministry of Digitization news release on adoption steps at Rozwój sztucznej inteligencji w Polsce – important decision). The national policy document sets short‑ (to 2023), medium‑ (to 2027) and long‑term measures, with specific actions for each focus area.

Monitoring and Evaluation

The memorandum prescribes institutional monitoring through the coordinating ministry and appointed expert teams. Monitoring mechanisms include periodic progress reports, evaluation of pilot projects, tracking of R&D investments, and public disclosure of key outputs and milestones. Public consultations and stakeholder feedback are part of the evaluation cycle to ensure transparency and adaptivity. The memorandum created the expectation that a central coordination body will publish updates and maintain a public repository of materials and reports on the gov.pl AI portal (see Droga Polski do AI).

Penalties, Liability, and Appeals

As a non‑binding memorandum, it contains no unique penal or administrative sanctions. Instead, the memorandum relies on existing legal frameworks for liability and enforcement: civil liability rules, sectoral safety regulations, data protection law (GDPR) and applicable criminal or administrative rules remain in force for misuse or unlawful AI deployment. The document therefore frames responsibility in administrative and reputational terms: ministries are expected to embed legal compliance into procurement and funding conditions and to require conformity with data protection and non‑discrimination requirements in supported projects.

Relationship to Other Instruments

The memorandum explicitly references and seeks alignment with European Commission initiatives (the Coordinated Plan on AI, EU ethics guidelines) and with OECD recommendations. It served as a precursor and operational anchor for the "Polityka Rozwoju Sztucznej Inteligencji w Polsce na lata 2019–2027" (the national AI policy draft published for public consultation) and informed later national measures (funding streams, centers and GovTech projects). It does not formally override statutory law but complements EU and domestic legal instruments by specifying coordination mechanisms and policy priorities; see the ministry consultation page and timeline on the gov portal (see Droga Polski do AI — timeline).

International Alignment

The memorandum stresses alignment with international frameworks (EU ethics guidelines for trustworthy AI, the EU Coordinated Plan, OECD principles). It explicitly references the need to incorporate international best practices into national policy design and to participate in multilateral initiatives to ensure interoperability of technical standards, research cooperation and ethical safeguards. That international focus guided the policy drafting process and public consultations, as the government used EU and OECD documents as inputs to the national policy (see the gov timeline and linked EU/OECD references at Droga Polski do AI).

Implementation Timeline

Event	Date
Memorandum signed by ministries	2019-02-26
Public consultation announced (AI policy draft)	2019-08-21
Public consultations period (policy draft)	2019-08-22 to 2019-09-09
Expert groups and AI Tech academy announced	2019-11-20
Government committee adoption steps reported	2020-09-14

Compliance Checklist

Requirement	Action
Inter‑ministerial cooperation	Participate in working groups and share plans/data
Policy drafting and consultation	Contribute to consultations and implement agreed actions
Data protection compliance	Ensure all AI projects comply with GDPR and national privacy rules
Ethics and fundamental rights screening	Apply ethical impact assessments to pilots and procurements
Funding and reporting	Link funding to project conformity and publish progress reports

Sources and References

Source	Type
Konsultacje społeczne projektu „Polityki Rozwoju Sztucznej Inteligencji w Polsce na lata 2019–2027" (Ministry of Digitization)	Primary Source
Droga Polski do AI — government AI portal	Primary Source
Polityka Rozwoju Sztucznej Inteligencji w Polsce na lata 2019–2027 — attachment	Primary Source