Michał Kulesza


Advocate, heads the Financial Regulation and Technology Practice.


He specializes in regulatory issues related to IT. He provides ongoing legal services to financial sector entities in respect of regulatory issues (e.g., EBA, DORA, FSC guidelines), IT outsourcing, digitization and cloud services – both for ordering parties and solution providers for regulated sector entities.

Experience and education

He has managed cutting edge projects worth more than PLN 10bn, including negotiating a deal to set up Google and Microsoft regions in Poland and implementing pioneering cloud solutions in banks, insurance companies, investment funds and entities in the healthcare (medical and pharmaceutical), energy, critical infrastructure or telecommunications sectors. 

Graduate of the Faculty of Law and Administration at the University of Warsaw and the School of American Law organized by the Levin College of Law at the University of Florida. He has knowledge of the English language.

Michał Kulesza’s detailed experience:
  • Providing assistance to TFIs and a securitized debt manager in implementing cloud solutions. The assistance included auditing the company’s internal documentation, aligning its internal procedures with the requirements of the Communication, and ensuring regulatory compliance in connection with cloud computing both under the requirements of the Polish Financial Supervision Authority and the outsourcing provisions in the Law on Investment Funds and Alternative Investment Fund Management.
  • Assisting the Bank in the process of obtaining permission from the Polish Financial Supervision Authority for the implementation of Google G Suite services, the use of which has been classified as foreign outsourcing, pursuant to Article 6d of the Banking Law. The assistance included, inter alia, review of the Bank’s documentation and internal analyses, review of a contract, negotiations with the provider and support in drafting letters to the Polish Financial Supervision Authority.
  • Assisting the Insurance Group in implementing cloud-based solutions supplied by three service providers. The assistance included, inter alia, review of the client’s internal documentation, review of contracts, support in negotiating with suppliers and drafting notices of intent to implement outsourcing, as required by sectoral regulations.
  • Assisting the Insurance Group in implementing a procedure for assessing cloud projects in terms of legal and regulatory requirements, including in terms of projects qualifying as subject to insurance outsourcing regulations. The law firm’s assistance also included review of a contract with a cloud solution provider which the Insurance Group is planning to implement.
  • Assisting the Insurance Group in putting in place a procedure for reviewing cloud projects in terms of legal and regulatory requirements, including in terms of projects qualifying as subject to insurance outsourcing regulations, as well as assisting in bringing two cloud projects into line with the applicable requirements – in accordance with the procedure in effect.
  • Assisting the Polish Cloud Service Provider in drafting internal documentation aimed at ensuring compliance of the solutions offered by the provider with the regulatory requirements applicable in the financial sector and cloud services contracts meeting all requirements arising from the sector regulations and supervisory authority’s guidelines.
  • Assisting the National Cloud Operator in negotiating a strategic partnership agreement with Google and Microsoft, based on which Google Cloud and Azure regions are being set up in Poland. The assistance included drafting transaction documentation, contract negotiation and closing, as well as compliance testing for the provision of services by the National Cloud Operator to end entities.
  • Other projects involving assistance in ensuring compliance of IT solutions with regulatory requirements, including review of financial institutions’ internal documentation, providers’ documentation, contracts with providers, negotiations with providers aimed at bringing the terms of service into line with legal and regulatory requirements, as well as assistance in the course of regulatory inspections and exchange of communications with the regulator.


Please feel free to contact me on matters concerning the regulated sector, including regulatory issues, IT outsourcing, digitization or cloud solutions (IaaS/SaaS/PaaS).