KC
Katia Ciesielska
INDEPENDENT NON-EXECUTIVE DIRECTOR
DISCUSS A MANDATE
AI GOVERNANCE

AI oversight is a board responsibility.

AI oversight belongs in the boardroom. I help Luxembourg boards understand where AI is used across their organisation and its service providers, challenge the risks, and establish clear accountability.

Katia Ciesielska · Luxembourg independent non-executive director and co-author of ILA’s AI in the Boardroom: Opportunities, Risk and Board Oversight.

Discuss your board’s AI priorities →
HOW I CAN HELP

Board advisory

Support with AI oversight priorities, questions for delegates and the governance arrangements your board needs to review. We agree a focused scope around your organisation’s exposure.

DISCUSS ADVISORY SUPPORT →

In-house AI governance training

A tailored session for boards and executive committees on AI use, accountability, risk and EU AI Act readiness. Available at your premises or online, in English, French or German.

ENQUIRE ABOUT TRAINING →

Speaking and moderation

Keynotes, panels and moderated discussions that connect AI developments with the decisions directors face. The topic and format are agreed around your audience.

VIEW SPEAKING & TRAINING →
WHERE THE EXPOSURE ACTUALLY SITS

Most fund boards look for AI in the wrong place.

A Luxembourg fund may have no employees and no systems of its own. The AI is at the delegates: the AIFM, the central administrator, the transfer agent, the AML screening vendor. It arrives as a feature of an existing service rather than as a new one, which is why it rarely reaches the board.

In my experience AI appears in board packs as an innovation topic, and almost never in the section where the board reviews its service providers.

What AI is embedded in the services you deliver to us, and how are the AI Act obligations allocated between us?

THE GOVERNANCE GAP

Deployment has outrun oversight.

28%
of surveyed Luxembourg financial-sector entities had AI in production or development
The survey covered banks, investment firms, authorised fund managers, payment institutions and e-money institutions. Responses were collected in 2024.
35%
of surveyed directors said their boards had incorporated AI and generative AI into oversight
PwC’s survey examines US corporate boards. It provides an international comparison, rather than a measure of Luxembourg practice.
66%
of respondents described their boards’ AI knowledge or experience as limited or absent
Deloitte surveyed 695 board members and senior executives across 56 countries in January and February 2025.

These surveys cover different populations and periods; the figures are context, not a like-for-like comparison.

WHAT THE BOARD OWNS

Seven commitments set out in AI in the Boardroom, the ILA guidance I co-authored with the Research Think Tank.

To govern AI, boards must elevate.

E
Educate
Invest in AI literacy for all directors.
L
Legislate internally
Establish governance frameworks with defined accountability.
E
Evaluate
Implement risk-based approval processes for AI tools.
V
Verify compliance
With confidentiality, data protection and the EU AI Act.
A
Anchor human judgment
As the foundation of board decision-making.
T
Test and adapt
Regularly review and evolve AI governance.
E
Ensure safety
Protect the deliberative quality and psychological safety of board processes.
WHERE A BOARD STARTS

What the board should require, in what order. Visibility before controls, controls before scale.

The first ninety days.

WEEKS 1–2
Require visibility
Ask for an inventory of material AI use across the entity and its delegates, with a named owner for each use case.
WEEKS 3–4
Challenge classification
Require each use case to be classified by risk under the AI Act, and the organisation’s role — deployer or provider — to be confirmed and recorded.
WEEKS 5–8
Approve the framework
Approve the oversight, escalation and assurance arrangements for material AI use, including where human sign-off sits.
WEEKS 9–12
Receive assurance
Take the inventory as a standing item, and set the frequency at which AI governance returns to the board.

The regulatory timetable.

What applies depends on the AI system, its use and the organisation’s role. Boards should ask management to document that assessment.

2 August 2026
Article 50 transparency obligations apply, with transitional provisions for certain existing systems.
2 December 2027
High-risk requirements for systems listed in Annex III apply.
2 August 2028
High-risk requirements for AI embedded in regulated products under Annex I apply.

European Commission implementation timeline →

Article 99 sets maximum fines of EUR 15 million or 3% of worldwide annual turnover for specified infringements, and EUR 35 million or 7% for prohibited practices. The higher ceiling generally applies to undertakings, with specific lower-ceiling rules for SMEs and, for certain infringements, small mid-cap companies. Read Article 99.

Regulatory information last reviewed: .

ON THE RECORD

Published and presented.

Co-author of the ILA’s board guidance on AI, and a regular speaker on AI governance and EU AI Act readiness across Luxembourg and Brussels.

COMING UP
18
NOV 2026
TRAINER · ILA
Introduction to Artificial Intelligence for CGOs
Venue and CPD to be confirmed with ILA
REGISTER
08
DEC 2026
TRAINER · ILA
Artificial Intelligence for Boards
Chamber of Commerce, Luxembourg · 4 CPD hours
REGISTER
PUBLICATIONS
CO-AUTHOR · ILA · 2026
EXECUTIVE EDUCATION
Artificial Intelligence: Implications for Business Strategy
MIT SLOAN · 2025
SELECTED ENGAGEMENTS
Nacha Payment Innovation Alliance, Brussels — EU AI Act and its implications for banks and payment systems
2026
PwC NED Day — AI in the Boardroom: governance, risk, opportunity and practical use
2026
Funds Directors’ Forum — Practical use of AI by iNEDs
2026
Nexus Luxembourg — AI governance, EU AI Act readiness and board oversight
2026
Luther Spring Event — AI panel
2026
Guberna, Brussels — AI for General Secretaries
2025
Dinamik 20th Anniversary — Regulation and AI in fund administration
2025

Frequently asked questions

What does AI governance mean for a Luxembourg fund board?

It means understanding where AI is used across the fund, its manager and its service providers, who is accountable, and what evidence supports the controls. The board should ask how AI use fits within existing delegation, risk and oversight arrangements, and which AI Act obligations apply to each organisation and use case.

What experience do you bring to AI oversight?

I am a Luxembourg independent non-executive director and co-author of ILA’s AI in the Boardroom: Opportunities, Risk and Board Oversight and New Technologies for Board Minutes. My speaking and training experience includes PwC NED Day, ILA programmes and the Nacha Payment Innovation Alliance in Brussels. I connect those topics with the practical work of overseeing regulated entities and their delegates.

Can you train our board in-house?

Yes. I offer AI governance training for boards and executive committees at your premises or online, in English, French or German. We agree the duration and content around your organisation’s AI exposure and the questions your directors need to address. Enquire about a tailored session.

What does an initial engagement involve?

We start by discussing your organisation, the AI questions already reaching the board and the outcome you need. We then agree the scope, format and timing, whether that is a board briefing, a training session or focused advisory support. Discuss your board’s priorities.

What is the ELEVATE framework?

ELEVATE is the framework set out in the ILA guidance I co-authored: Educate, Legislate internally, Evaluate, Verify compliance, Anchor human judgment, Test and adapt, and Ensure safety. It helps boards turn AI oversight into specific responsibilities and questions. Read the ILA publication.

START A CONVERSATION

What does your board need to resolve?

For AI governance advisory, a tailored board briefing or a speaking engagement, let’s discuss your priorities.

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