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

AI oversight is a board responsibility.

Not a technology project delegated downwards. The EU AI Act creates obligations across the organisations and service providers that fund boards oversee. The first challenge is knowing where AI is actually being used, and who owns the resulting obligations.

2026
Article 50 transparency obligations applicable from 2 August
2027
Annex III high-risk requirements apply from 2 December
2028
Annex I high-risk systems embedded in regulated products, from 2 August
3%
Up to EUR 15 million or 3% of worldwide annual turnover for certain infringements, whichever is higher
7%
Or EUR 35 million, the ceiling reserved for prohibited practices
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.

43%
of Luxembourg financial-sector firms are already deploying AI
Primarily for internal efficiency, and expected to rise sharply.
BCL / CSSF THEMATIC REVIEW, MAY 2025
35%
of directors say their boards have incorporated AI into oversight activities
One in three say AI does not appear on board agendas at all.
PWC ANNUAL CORPORATE DIRECTORS SURVEY, 2025
66%
of directors say their boards have limited to no knowledge of AI
The capability gap, rather than the technology, is the constraint.
MCKINSEY GLOBAL SURVEY, 2025
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.
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
05
OCT 2026
SPEAKER · ILA FLAGSHIP EVENT
CGO 2.0: Evolving Roles in a Digital Landscape
Arendt House, Luxembourg · 1 CPD hour
REGISTER
18
NOV 2026
TRAINER · ILA
Introduction to Artificial Intelligence for CGOs
Chamber of Commerce, Luxembourg · 4 CPD hours
REGISTER
08
DEC 2026
TRAINER · ILA
Artificial Intelligence for Boards
Chamber of Commerce, Luxembourg · 4 CPD hours
REGISTER
PUBLICATIONS
AI in the Boardroom: Opportunities, Risk and Board Oversight
CO-AUTHOR · ILA · 2026
New Technologies for Board Minutes
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
START A CONVERSATION

Looking for an independent perspective?

For board appointments, governance advisory or speaking enquiries, I would be pleased to hear from you.

KATIA@KATIACIESIELSKA.COM →
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