Cited by 2Digitalization, Law, and RegulationEthics and Social Impacts of AIRegulation and Compliance Studies

Emerging models of national competent authorities under the EU AI Act

Open access
Parisini, Emanuele, Dervishaj, Eduard·2025·Conference on Digital Government Research

Abstract

This paper examines the emerging models of national competent authorities under the European Union's Artificial Intelligence Act (AI Act), providing novel insights into how different jurisdictions approach AI governance institutionalization. Through systematic analysis of official documents from early implementing Member States, we identify three fundamental dimensions that characterize distinct regulatory approaches. First, the organizational architecture reveals a spectrum from centralized to fragmented oversight models, reflecting different philosophies about coordinated versus distributed AI governance. Second, the institutional choices between leveraging existing regulatory bodies versus establishing new AI-specific authorities highlight contrasting approaches to building governance capacity and expertise. Third, the regulatory scope demonstrates a critical divide between horizontal and vertical oversight frameworks, with some jurisdictions pioneering hybrid solutions that attempt to balance specialized knowledge with coordinated supervision. Our methodology combines document analysis of legislative proposals, government resolutions, and administrative acts with a three-dimensional analytical framework examining degrees of centralization, institutional arrangements, and oversight models. The findings contribute to the theoretical understanding of AI governance by revealing how different jurisdictions interpret and operationalize regulatory requirements, balance competing institutional priorities, and address the complex challenge of overseeing AI systems. Furthermore, the analysis offers insights into the evolution of AI governance structures and contributes to the broader discourse on institutional design for emerging technology oversight. While our analysis is limited to early implementers and based primarily on formal documents rather than operational evidence, it provides a foundation for future research examining the effectiveness of different models, their evolution over time, and their impact on AI innovation and oversight. Future studies could benefit from comparative analyses of implementation outcomes, stakeholder perspectives, and the practical challenges of operationalizing these different governance frameworks.

AI snapshot

Written from the paper’s full text.

TL;DR

The paper maps early national implementation of the EU AI Act’s competent-authority requirements, identifying three dimensions: centralization, existing vs. new bodies, and horizontal vs. vertical oversight. It finds fragmented, existing-body, and mixed oversight models dominate among early implementers, while centralized and new AI-specific bodies appear in Hungary, Italy, and Poland.

Key findings

  • As of April 2025, most EU Member States had not taken official legislative steps to appoint notifying or market surveillance authorities; the paper lists 19 such states (Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, France, Germany, Greece, Ireland, Latvia, Netherlands, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden), and none of Iceland, Norway, or Liechtenstein had appointed authorities before April 2025. Cyprus and Malta identified authorities on government websites but had no implementing law, marked as planned.
  • Three organizational approaches emerge: fragmented is predominant among early implementers (Finland, Lithuania, Luxembourg, Malta), centralized appears in Hungary, Italy, and Poland, and unified is adopted only at EU level through the European Data Protection Supervisor. Luxembourg is described as an eight-authority framework; Lithuania uses a dual-agency model.
  • Institutional choice: most early implementers leverage existing bodies (Finland, Luxembourg, Malta, Italy); only Hungary and Poland create new AI-specific bodies (Hungarian Artificial Intelligence Council; Polish Artificial Intelligence Development and Security Commission).
  • Oversight scope: vertical/domain-specific models appear in Finland and Luxembourg, comprehensive/horizontal models in Hungary and Poland, and hybrid solutions in Cyprus and Malta. The AI Act deadline for appointing national competent authorities is 2 August 2025.

Methods

  • Document analysis of official legislative and administrative sources from EU Member States, covering four categories: legislative proposals, government resolutions and administrative acts, official online communications, and draft laws/amendments. Selection required documents to explicitly address AI Act Articles 28 and 70, represent formal government positions, and contain specific institutional details; Cyprus and Malta were supplemented with correspondence with officials.
  • Temporal framework runs from the AI Act’s entry into force in August 2024 to the data collection cutoff in April 2025, with the AI Act’s appointment deadline of 2 August 2025 noted.
  • Comparative analysis uses a three-dimensional framework—centralization, institutional choice, and oversight scope—and clustering via a comparative matrix mapping type of national authority and governance approach (government control vs. independent body), followed by three sequential clustering steps.

Limitations

  • Paper-stated: the analysis is limited to early implementing Member States during the initial months after the AI Act’s entry into force; it relies primarily on formal documents and legislative proposals rather than operational evidence because authorities are not yet fully functioning; current institutional arrangements may evolve; translations introduce interpretive considerations and risk of misinterpretation.
  • Paper-stated: findings may not reflect the complete EU-wide implementation landscape; future research is needed on effectiveness, evolution over time, stakeholder perspectives, coordination mechanisms, and practical implementation challenges.
  • Evident from the text: the April 2025 cutoff and Table 1’s January 2025 update mean later designations or legislation are not captured; Cyprus and Malta are marked planned with no implementing law, so their models are provisional; no empirical assessment of governance outcomes or effectiveness is presented.

Model-written summary. Check it against the paper before relying on it.

Integrity signals

Registry

Crossref · 10.59490/dgo.2025.1007

Cites

24 of 24 references verified0 citation errors · 0 not checkable

Statistics

Nothing to recompute.

Claims the paper makes

1 of 11 cited sources checked · 0 supported · 0 flagged · accuracy not yet measured

  • Findingreasoning

    Hungary established a new Hungarian Artificial Intelligence Council to perform both notifying and market surveillance tasks under the AI Act.

    “Hungary established the new Hungarian Artificial Intelligence Council, which shall perform the official tasks both of notifying and market surveillance authorities under the AI Act.”
    Quote in the paperSubstantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • Findingnone given

    The centralized approach, adopted by Hungary, Italy, and Poland, places both market surveillance and notifying authority functions under direct government control.

    “The centralized approach, adopted by Hungary, Italy, and Poland, places both market surveillance and notifying authority functions under direct government control.”
    Quote in the paperSubstantial claim
  • Findingnone given

    Finland's proposal distributes market surveillance across multiple existing government regulatory bodies rather than creating a single centralized authority.

    “The Finnish proposal distributes oversight responsibilities of market surveillance across multiple existing government regulatory bodies rather than creating a single centralized authority.”
    Quote in the paperNot a substantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • Findingown data

    In April 2025, most EU Member States had not taken official legislative steps to appoint either the notifying authority or the market surveillance authority.

    “In April 2025, most of the EU countries did not take official legislative steps to appoint neither the notifying authority, nor the market surveillance authority.”
    Quote in the paperSubstantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • Findingcitation

    The work of the Artificial Intelligence Development and Security Commission will be managed by a Chairman appointed by the Prime Minister of Poland.

    “The work of the Commission will be managed by the Chairman appointed by the Prime Minister of Poland.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Government bill n.UC71 of 2024

      Couldn’t be matched to a paper in Crossref, so it can’t be checked.

  • Classified as probably not a substantial claim. 12
  • May combine two claims. 24
  • The quote only partly states this claim. 1
  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Interpretationcitation

    This approach suggests a pragmatic strategy that capitalizes on established regulatory expertise and existing strong institutional frameworks (Winfield, 2018).

    “This approach suggests a pragmatic strategy that capitalizes on established regulatory expertise and existing strong institutional frameworks (Winfield, 2018).”
    Quote in the paperNot a substantial claim1 of 1 sources checked
    • cites Winfield, 2018 source

      In “Building the roadmap” (page not provided), the paper proposes regulating some robots through a body similar to the Civil Aviation Authority, supporting the idea of drawing on established regulatory models. The “Concluding discussion” (page not provided) calls for strong institutional frameworks, but does not establish that such frameworks already exist and can be used by the proposed approach. (LLM, conf=0.82)

      Experimental — accuracy not yet measured
  • May combine two claims.

    Findingnone given

    While most EU countries have yet to designate their competent authorities, the emerging patterns from early adopters provide valuable insights into different implementation strategies.

    “While most EU countries have yet to designate their competent authorities, the emerging patterns from early adopters provides valuable insights into different implementation strategies.”
    Quote in the paperSubstantial claim
  • May combine two claims. The quote only partly states this claim.

    Findingreasoning

    Cyprus divided responsibilities between two existing regulatory bodies, with the Commissioner for Communications serving as notifying authority, market surveillance authority, and single point of contact.

    “The Commissioner for Communications serves multiple key roles: notifying authority, market surveillance authority, and the single point of contact”
    Quote in the paperNot a substantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • May combine two claims.

    Findingown data

    Lithuania designated the Innovation Agency as notifying authority and the Communications Regulatory Authority (RRT) as market supervisor and single point of contact.

    “The Innovation Agency has been designated as the national notifying authority, while the Communications Regulatory Authority will act as the market supervisor and single point of contact.”
    Quote in the paperNot a substantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • May combine two claims.

    Findingown data

    Regulatory scope for AI oversight under the AI Act varies between horizontal and vertical frameworks, with some jurisdictions pioneering hybrid solutions.

    “regulatory scope demonstrates a critical divide between horizontal and vertical oversight frameworks”
    Quote in the paperSubstantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • May combine two claims.

    Findingnone given

    Italy proposed the National Cybersecurity Agency (ACN) as market surveillance authority and the Agency for Digital Italy (AgID) as notifying authority.

    “proposed to appoint the National Cybersecurity Agency (ACN) as market surveillance authority with monitoring, inspection and enforcement powers, and the Agency for Digital Italy (AgID) as notifying authority.”
    Quote in the paperNot a substantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Findingcitation

    It is proposed to designate the Department of Digital Affairs of the Chancellery of the Prime Minister of Poland as the authority responsible for notification of conformity assessment bodies and as the notifying authority.

    “It is also proposed to designate the Department of Digital Affairs of the Chancellery of the Prime Minister of Poland, the institution responsible for computerization, as the authority responsible for notification of conformity assessment bodies and as the notifying authority.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Government bill n.UC71 of 2024

      Couldn’t be matched to a paper in Crossref, so it can’t be checked.

  • May combine two claims.

    Findingreasoning

    Luxembourg designated the Commission for Data Protection (CGPD) as the horizontal market surveillance authority by default and single point of contact.

    “the Commission for Data Protection (Commissariat du gouvernement à la protection des données auprès de l'Etat, CGPD) is responsible for coordination with market surveillance authorities and designated as the single point of contact.”
    Quote in the paperNot a substantial claim
    • Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
  • May combine two claims.

    Findingnone given

    Hungary and Poland have opted to establish new AI-specific bodies.

    “In contrast, Hungary and Poland have opted to establish new AI-specific bodies.”
    • Also stated in: § 6. Conclusion · plain
      “Only Hungary and Poland opted to create new dedicated AI oversight bodies, highlighting different philosophies about building regulatory capacity.”
    Quote in the paperSubstantial claim
  • May combine two claims.

    Findingown data

    The fragmented approach emerges as the predominant choice among early implementers, with countries like Finland, Lithuania, Luxembourg, and Malta adopting various mixed models.

    “The fragmented approach emerges as the predominant choice among early implementers, with countries like Finland, Lithuania, Luxembourg, and Malta adopting various mixed models.”
    • Also stated in: § 6. Conclusion · plain
      “The fragmented approach emerges as predominant, with countries like Finland, Lithuania, Luxembourg, and Malta distributing responsibilities across multiple bodies.”
    Quote in the paperSubstantial claim
  • May combine two claims.

    Findingown data

    The results reveal a clear dichotomy in institutional approaches to AI oversight, with most Member States opting to leverage existing regulatory bodies while only a few create new AI-specific institutions.

    “The results also reveal a clear dichotomy in institutional approaches to AI oversight, with most Member States opting to leverage existing regulatory bodies while only a few create new AI-specific institutions.”
    Quote in the paperSubstantial claim
  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Findingnone given

    The unified approach has only been adopted by EU institutions through the European Data Protection Supervisor (EDPS).

    “The unified approach, interestingly, has only been adopted by EU institutions through the European Data Protection Supervisor (EDPS).”
    Quote in the paperNot a substantial claim
  • May combine two claims.

    Findingreasoning

    Luxembourg's implementation exemplifies the fragmented approach, with multiple sectoral authorities sharing market surveillance responsibilities while maintaining the National Commission for Data Protection as a horizontal coordinator.

    “Luxembourg's implementation particularly exemplifies this approach, with multiple sectoral authorities sharing market surveillance responsibilities while maintaining the National Commission for Data Protection as a horizontal coordinator.”
    Quote in the paperNot a substantial claim
  • May combine two claims.

    Interpretationreasoning

    Poland has opted for a primarily consolidated regulatory architecture with clearly defined jurisdictional boundaries.

    “Poland has opted for a primarily consolidated regulatory architecture with clearly defined jurisdictional boundaries.”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.

    Interpretationreasoning

    The centralized approach suggests a preference for strong governmental coordination in AI oversight, potentially facilitating faster decision-making and unified policy implementation.

    “This approach suggests a preference for strong governmental coordination in AI oversight, potentially facilitating faster decision-making and unified policy implementation.”
    Quote in the paperNot a substantial claim
  • May combine two claims.

    Interpretationreasoning

    Poland's approach reflects a strategic decision to create dedicated AI governance institutions rather than distributing responsibilities across existing regulatory bodies, enabling more focused expertise development while maintaining centralized coordination.

    “This approach reflects Poland's strategic decision to create dedicated AI governance institutions rather than distributing responsibilities across existing regulatory bodies, enabling more focused expertise development while maintaining centralized coordination.”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S2 (checkable), S4 (based).

    Interpretationnone given

    These divergent implementation strategies reflect fundamental differences in administrative traditions, institutional capacities, and conceptualizations of effective technology governance across the European regulatory landscape.

    “These divergent implementation strategies reflect fundamental differences in administrative traditions, institutional capacities, and conceptualizations of effective technology governance across the European regulatory landscape.”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.

    Interpretationreasoning

    The unified model combines both functions within a single independent authority, potentially offering clearer lines of accountability and more streamlined operations.

    “This model combines both functions within a single independent authority, potentially offering clearer lines of accountability and more streamlined operations.”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S2 (checkable), S3 (load-bearing), S4 (based).

    Interpretationreasoning

    It may also reflect practical considerations regarding the ambitious implementation timeline, as creating entirely new institutions by August 2025 could present significant organizational challenges.

    “It may also reflect practical considerations regarding the ambitious implementation timeline, as creating entirely new institutions by August 2025 could present significant organizational challenges.”
    Quote in the paperNot a substantial claim
  • May combine two claims.

    Interpretationreasoning

    While centralized approaches might offer more straightforward coordination, fragmented implementations might better address the multifaceted nature of AI regulation, from technical standards to market surveillance duties.

    “While centralized approaches might offer more straightforward coordination, fragmented implementations might better address the multifaceted nature of AI regulation, from technical standards to market surveillance duties.”
    Quote in the paperNot a substantial claim
  • May combine two claims.

    Interpretationcitation

    The institutional continuity approach also presents potential challenges: existing bodies may need significant adaptation to handle AI-specific oversight responsibilities, and there might be risks of institutional path dependency (Chiodo, 2024), limiting the development of novel regulatory approaches needed for AI governance.

    “However, the institutional continuity approach also presents potential challenges.Existing bodies may need significant adaptation to handle AI-specific oversight responsibilities, and there might be risks of institutional path dependency (Chiodo, 2024), limiting the development of novel regulatory approaches needed for AI governance.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Chiodo, 2024

      Couldn’t be matched to a paper in Crossref, so it can’t be checked.

  • May combine two claims.

    Interpretationcitation

    The limited adoption of the unified approach by Member States might suggest practical challenges in implementing this approach at the national level, where existing regulatory landscapes are more complex, the market presents more AI systems for market surveillance activities, and robust capacity in AI is needed, notably towards the need for public acceptance (Middleton, 2022).

    “However, its limited adoption by Member States might suggest practical challenges in implementing this approach at the national level, where existing regulatory landscapes are more complex, the market presents more AI systems for market surveillance activities, and robust capacity in AI is needed, notably towards the need for public acceptance (Middleton, 2022).”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Middleton, 2022 source
  • Classified as probably not a substantial claim. May combine two claims.

    Interpretationreasoning

    Hungary's creation of a dedicated AI Council and Poland's proposed Artificial Intelligence Development and Security Commission represent a more transformative approach to AI governance.

    “Hungary's creation of a dedicated AI Council and Poland's proposed Artificial Intelligence Development and Security Commission represent a more transformative approach to AI governance.”
    Quote in the paperSubstantial claim
  • May combine two claims.

    Interpretationreasoning

    New AI-specific bodies might offer more flexibility in developing tailored oversight mechanisms, but they face the substantial challenge of building institutional capacity and expertise within a limited timeframe.

    “Conversely, while new AI-specific bodies might offer more flexibility in developing tailored oversight mechanisms, they face the substantial challenge of building institutional capacity and expertise within a limited timeframe.”
    Quote in the paperSubstantial claim
  • May combine two claims.

    Interpretationreasoning

    Organizational fragmentation potentially enhances the depth of domain-specific understanding but simultaneously creates significant coordination burdens and risks of inconsistent implementation across regulatory domains.

    “This organizational fragmentation potentially enhances the depth of domainspecific understanding but simultaneously creates significant coordination burdens and risks of inconsistent implementation across regulatory domains.”
    Quote in the paperSubstantial claim
  • May combine two claims.

    Interpretationreasoning

    These new institutions might offer advantages in terms of specialized focus and clear mandate, but they also face the challenge of building regulatory capacity and expertise from the ground up.

    “These new institutions might offer advantages in terms of specialized focus and clear mandate, but they also face the challenge of building regulatory capacity and expertise from the ground up.”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S2 (checkable), S3 (load-bearing), S4 (based). May combine two claims.

    Interpretationreasoning

    This institutional design dichotomy reflects deeper theoretical questions regarding the nature of effective technology governance - specifically, whether novel technological systems like artificial intelligence represent extensions of existing regulatory domains requiring evolutionary adaptation or fundamentally different governance challenges necessitating revolutionary institutional tran

    “This institutional design dichotomy reflects deeper theoretical questions regarding the nature of effective technology governance -specifically, whether novel technological systems like artificial intelligence represent extensions of existing regulatory”
    Quote in the paperNot a substantial claim
  • Probably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.

    Interpretationcitation

    The choice to create new bodies might reflect these countries' vision of AI oversight as a distinct regulatory domain requiring dedicated institutional frameworks rather than an extension of existing regulatory functions, highlighting the tension in diverse AI public management and organization (Selten, 2024).

    “The choice to create new bodies might reflect these countries' vision of AI oversight as a distinct regulatory domain requiring dedicated institutional frameworks rather than an extension of existing regulatory functions, highlighting the tension in diverse AI public management and organization (Selten, 2024).”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Selten, 2024 source
  • May combine two claims.

    Interpretationreasoning

    By distributing responsibilities across existing bodies, Member States can potentially meet the August 2025 deadline while leveraging established regulatory expertise.

    “By distributing responsibilities across existing bodies, Member States can potentially meet the August 2025 deadline while leveraging established regulatory expertise.”
    Quote in the paperSubstantial claim
  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Interpretationreasoning

    Building on existing institutions might facilitate faster operational capability and more efficient resource utilization, particularly important given the comprehensive expertise requirements outlined in Article 70(3) of the AI Act.

    “Moreover, building on existing institutions might facilitate faster operational capability and more efficient resource utilization, particularly important given the comprehensive expertise requirements outlined in Article 70(3) of the AI Act.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites Article 70(3)

      Couldn’t be matched to a paper in Crossref, so it can’t be checked.

  • Probably not a substantial claim: may not pass S2 (checkable), S3 (load-bearing).

    Interpretationreasoning

    The distributed approach operationalizes theoretical insights regarding the diversity of expertise necessary for effective technology governance, acknowledging that different regulatory domains require distinct forms of specialized knowledge that may not be readily consolidated within singular institutional structures.

    “The distributed approach operationalizes theoretical insights regarding the diversity of expertise necessary for effective technology governance, acknowledging that different regulatory domains require distinct forms of specialized knowledge that may not be readily consolidated within singular institutional structures.”
    Quote in the paperNot a substantial claim
31 of 31
  • The paper relies on this without support.

    Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.

    “The document analysis process relied on official legislative and administrative sources from EU Member States.”
  • The paper relies on this without support.

    Translations from original languages do not materially distort the analysis of institutional arrangements.

    “we based our research on documents in their original languages, employing translations, when necessary, which inevitably introduces interpretive considerations and risk of misinterpretation.”
2 of 2

Self-check

Percentages, sums and reported differences re-computed from the paper’s own numbers.

Each contradiction between two passages listed here was confirmed by an independent check.

  • Luxembourg's second notifying authority differs between text and table

    Major

    The Luxembourg section names the Government Data Protection Commission as a notifying authority, whereas Table 1 names the National Commission for Data Protection.

  • Fountain citation year differs from the reference

    Minor

    The text cites Fountain as a 2004 publication, but the corresponding reference lists 2001.

  • Laux citation year differs from the reference

    Minor

    The text cites Laux as a 2024 publication, but the corresponding reference lists 2023.

  • Luxembourg's coordinating authority is identified differently

    Minor

    The Luxembourg case designates the Government Data Protection Commission (CGPD) to coordinate market surveillance authorities, but the discussion identifies the National Commission for Data Protection (CNPD) as the coordinator.

4 of 4

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Authors
Parisini, E., & Dervishaj, E.
Affiliations
University of Pisa (IT)
Venue
Conference on Digital Government Research
Published
2025-05-22
ISSN
  • 3050-8681 (ISSN-L)
  • 1944-4907
OpenAlex
W4410587279
Cited by
2
References
22
Citations by year
2026: 2
FWCI
22.27
Type
conference paper
Language
en
Open access
Locations
  • Conference on Digital Government Research (publishedVersion, cc-by)
  • CINECA IRIS Institutial research information system (University of Pisa) (submittedVersion)
Topics
  • Social Sciences › Law › Digitalization, Law, and Regulation
  • Social Sciences › Safety Research › Ethics and Social Impacts of AI
  • Social Sciences › Business, Management and Accounting › Strategy and Management › Regulation and Compliance Studies
Keywords
EU AI Act, national competent authorities, AI governance, institutional design, regulatory implementation, member states

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