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AI in banking and insurance under KNF supervision

SAIE for banks and insurers is a layer for controlling and working with AI in which every AI-supported decision has an author, data and the audit trail required by supervisors. AI under KNF supervision: every decision has an author, data and a trace

Why now

Banks and insurers must show who authorised an AI-supported decision and on what data. DORA, the AI Act and ISO/IEC 42001 overlap, client data must not leave the organisation, and clients test the limits of models in service channels. A pilot that cannot be defended before the supervisor will not reach production. On 22 July 2026, KNF (Polish Financial Supervision Authority) issued recommendations on Frontier AI models, and AI is among the supervisory priorities of UKNF (Office of the Polish Financial Supervision Authority) for 2026. From 28 October 2026, KNF is part of KRiBSI (Commission for the Development and Security of Artificial Intelligence), which oversees the application of the AI Act. Since 17 January 2025, DORA has required AI providers to be included in the register of ICT contractual arrangements

Three people who need to say “yes”

Operations / risk director — faster document analysis with certainty about sources

CISO — client data stays in the organisation, protection against manipulation

Compliance / AI Officer — an inventory of AI systems and evidence for the supervisor

Business scenarios

Budgets and AI cost control

Cost and efficiency

PROXY:AI

Problem: Spending on language models is unpredictable and not assigned to an owner

How it works: Hierarchical budgets per team and project, with a policy for when the limit is exceeded: block, downgrade the model or raise an alert

What you gain: Every zloty spent on AI has an owner and a limit, and exceeding the budget triggers a predefined response

Document analysis with source verification

Knowledge and documents

TWIN:DESK

Problem: Analysing contracts, applications and claims files requires certainty about the source of every piece of information

How it works: A central RAG knowledge base with source preview and a Knowledge Gap Register; OCR of scanned documents

What you gain: The analyst sees which document each piece of information comes from, and the system says plainly when the file lacks a basis

Safe AI work with client data

Security and sovereignty

PROXY:AI

Problem: Client data must not reach a model outside the organisation

How it works: Model routing based on data sensitivity, detection and masking of personal data, and a predefined Finance sector profile

What you gain: Staff use the best models for general work, and client data goes only to the local environment — automatically

Protecting models against manipulation and abuse

Security and sovereignty

PROXY:AI

Problem: Clients try to manipulate the model in service channels

How it works: Real-time abuse detection: injection, jailbreak, prohibited content and token-usage anomalies

What you gain: An AI service channel that resists attempts to extract data or bypass the rules — and every attempt leaves a trace

A full audit trail of AI-supported decisions

Compliance and oversight

PROXY:AI

Problem: The supervisor requires evidence of who authorised an AI-supported decision and on what data

How it works: A cryptographically signed, immutable log of every call (Article 12 of the AI Act) with retention, and a Human Oversight mechanism (Article 14) with approval gates

What you gain: The answer for the supervisor is in the system: who, when, on what data and with what result — without reconstruction

Informed approval of AI-supported decisions

Compliance and oversight

CDF

Problem: An employee approves an AI recommendation without really checking it

How it works: Human Competence Gate (CDF-F2) — before a critical decision is approved, the system asks 5–15 check questions; too few correct answers block approval

What you gain: Human oversight stops being a “click approve” fiction — and you can prove it to the auditor

Inventory and risk classification of AI systems

Compliance and oversight

PROXY:AI + CDF

Problem: The regulator asks for an inventory of AI systems and their risk classification

How it works: CDF-F1.5: AI Act readiness assessment, statement of applicability and impact assessment report; PROXY:AI: a register of models and policies and the decision history as material for ISO/IEC 42001

What you gain: An inventory of AI systems with risk classification, ready for the supervisor’s request — kept up to date, not built for an inspection

Evidence

Production deployments in financial supervision institutions

Finance sector profile, mapped to DORA, the AI Act, ISO/IEC 42001 and NIST AI RMF

How we start

A technical meeting with the CISO and compliance, followed by a Proof of Value on the claims or credit documentation analysis process — with the Human Competence Gate from day one

Questions decision-makers ask

How can you limit hallucinations in banking applications?

By answering only from approved documents, with a source citation, and through human oversight of the decision. TWIN:DESK answers based on the organization’s documents with a citation, and PROXY:AI lets you route tasks to models proven in a given use case

How do you assess an AI provider and avoid concentration?

By being able to swap the model without rebuilding the process. PROXY:AI provides a single gateway to more than 100 models, both cloud and local. Changing a model is a configuration change, not a new deployment

Bielik and PLLuM

How do you include an AI provider in the register of ICT contractual arrangements (DORA)?

Like any ICT service provider supporting important functions: with a risk assessment, an exit plan and information on data location. The WORM log in PROXY:AI documents which models processed data and when

All questions

Other paths: Finance and professional services

Law firm

AI for lawyers with no invented case references and no case files in someone else’s chatbot

Accounting firm

AI that reads invoices, tracks deadlines and keeps client data separate

Business consulting

Faster deliverables, expert knowledge retained in the firm, client data kept separate

https://www.allclouds.pl/en/oferta-branzowa/finanse-i-ubezpieczenia/