Emerging models of national competent authorities under the EU AI Act
Open accessAbstract
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
Cites
Statistics
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.
- Findingreasoning
Luxembourg designated the National Commission for Data Protection as market surveillance authority for high-risk AI systems used by law enforcement and other sectors.
“designates the National Commission for Data Protection as the market surveillance authority for high-risk AI systems used by law enforcement and other sectors”
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
Institutional choices for national competent authorities under the AI Act vary between leveraging existing regulatory bodies and establishing new AI-specific authorities.
“institutional choices between leveraging existing regulatory bodies versus establishing new AI-specific authorities”
Quote in the paperSubstantial claim- Rests on an assumption: Official documents and government websites accurately reflect Member States' actual institutional arrangements and implementation models.
- Findingown data
The organizational architecture of national competent authorities under the AI Act varies along a spectrum from centralized to fragmented oversight models.
“organizational architecture reveals a spectrum from centralized to fragmented oversight models”
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 Hungarian model exemplifies the centralized approach through its establishment of the Artificial Intelligence Council under the direct supervision of the Minister of National Economy, creating a consolidated institutional structure with comprehensive authority over AI oversight functions.
“The Hungarian model exemplifies this approach through its establishment of the Artificial Intelligence Council under the direct supervision of the Minister of National Economy, creating a consolidated institutional structure with comprehensive authority over AI oversight functions.”
Quote in the paperNot a substantial claim - Findingown data
The analysis of early implementations of AI Act national competent authorities reveals three distinct organizational approaches among Member States.
“The analysis of early implementations of AI Act national competent authorities reveals three distinct organizational approaches among Member States.”
Quote in the paperSubstantial claim - Findingcitation
Poland's draft act on AI systems planned to establish a new market surveillance authority for AI models and systems, the Artificial Intelligence Development and Security Commission.
“The Polish draft act on artificial intelligence systems (Government bill n.UC71 of 2024) planned to establish a new market surveillance authority for artificial intelligence models and systems, which will be the Artificial Intelligence Development and Security Commission.”
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.
- Findingown data
Malta identified the Malta Digital Innovation Authority (MDIA) and Information Data Protection Commission (IDPC) as market surveillance authorities.
“the Malta Digital Innovation Authority (MDIA) and the Information Data Protection Commission (IDPC) have been identified as market surveillance authorities in Malta by the latest draft government law.”
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.
- Findingnone given
Italy appointed its National Cybersecurity Agency and Agency for Digital Italy for AI oversight.
“Similarly, Italy appointed its National Cybersecurity Agency and Agency for Digital Italy, while Malta leveraged the existence of its Digital Innovation Authority and the Data Protection Commission.”
Quote in the paperNot a substantial claim - Findingnone given
Finland distributed oversight responsibilities across established regulatory bodies in various sectors.
“Finland distributed oversight responsibilities across established regulatory bodies in various sectors, while Luxembourg designated existing authorities like the Institute for Standardization, Accreditation, Safety and Quality of Products and Services and National Data Protection Commission for different aspects of AI oversight.”
Quote in the paperNot a substantial claim - Findingnone given
Luxembourg designated existing authorities like the Institute for Standardization, Accreditation, Safety and Quality of Products and Services and National Data Protection Commission for different aspects of AI oversight.
“Luxembourg designated existing authorities like the Institute for Standardization, Accreditation, Safety and Quality of Products and Services and National Data Protection Commission for different aspects of AI oversight.”
Quote in the paperNot a substantial claim - Findingnone given
Within the fragmented landscape, institutional arrangements vary from moderately distributed (e.g., Lithuania's dual-agency model) to highly complex configurations (e.g., Luxembourg's eight-authority framework).
“Within this landscape, institutional arrangements vary from moderately distributed (e.g., Lithuania's dual-agency model) to highly complex configurations (e.g., Luxembourg's eight-authority framework).”
Quote in the paperSubstantial claim - Findingreasoning
The majority of early implementing states have chosen to adapt and expand the mandates of existing institutions.
“The majority of early implementing states have chosen to adapt and expand the mandates of existing institutions.”
- Also stated in: § 6. Conclusion · hedged
“Most early implementing states, including Finland, Luxembourg, Malta, and Italy, chose to expand the mandates of established authorities, likely capitalizing on existing expertise and institutional frameworks.”
Quote in the paperSubstantial claim - Also stated in: § 6. Conclusion · hedged
- Findingnone given
Malta leveraged the existence of its Digital Innovation Authority and the Data Protection Commission for AI oversight.
“Similarly, Italy appointed its National Cybersecurity Agency and Agency for Digital Italy, while Malta leveraged the existence of its Digital Innovation Authority and the Data Protection Commission.”
Quote in the paperNot a substantial claim - Findingnone given
Lithuania combines a government agency for notification with an independent authority for market surveillance.
“Similarly, Lithuania combines a government agency for notification with an independent authority for market surveillance.”
Quote in the paperNot a substantial claim - Findingreasoning
Poland's proposed Artificial Intelligence Development and Security Commission and Italy's designation of government agencies under the Presidency of the Council demonstrate variations of the centralized institutional design.
“Similarly, Poland's proposed Artificial Intelligence Development and Security Commission and Italy's designation of government agencies under the Presidency of the Council demonstrate variations of this centralized institutional design.”
Quote in the paperNot a substantial claim - Premisecitation
Articles 70 and 74 of the AI Act state that where Union institutions, bodies, offices or agencies fall within the scope of the AI Act, the EDPS shall act as the competent authority for their supervision, and as their market surveillance authority, except in relation to the Court of Justice of the European Union acting in its judicial capacity.
“In fact, artt.70 and 74 state that where Union institutions, bodies, offices or agencies fall within the scope of the AI Act, the European Data Protection Supervisor shall act as the competent authority for their supervision, and as their market surveillance authority, except in relation to the Court of Justice of the European Union acting in its judicial capacity.”
Quote in the paperSubstantial claim0 of 1 sources checked- cites artt.70 and 74
Couldn’t be matched to a paper in Crossref, so it can’t be checked.
- Premisecitation
For AI systems put into service or used by EU institutions, the AI Act references to national competent authorities or market surveillance authorities shall be construed as references to the European Data Protection Supervisor (EDPS).
“Finally, as regards AI systems put into service or used by European Union institutions, the AI Act references to national competent authorities or market surveillance authorities shall be construed as references to the European Data Protection Supervisor (EDPS).”
Quote in the paperNot a substantial claim0 of 1 sources checked- cites artt.70 and 74
Couldn’t be matched to a paper in Crossref, so it can’t be checked.
- Interpretationreasoning
The prevalence of the fragmented approach among early implementers might indicate a pragmatic response to the AI Act's comprehensive requirements.
“The prevalence of the fragmented approach among early implementers might indicate a pragmatic response to the AI Act's comprehensive requirements.”
Quote in the paperNot a substantial claim - Interpretationcitation
This choice also reflects the complexity of AI governance, where different aspects of oversight may require distinct types of regulatory approaches and expertise (Choi, 2023).
“However, this choice also reflects the complexity of AI governance, where different aspects of oversight may require distinct types of regulatory approaches and expertise (Choi, 2023).”
Quote in the paperNot a substantial claim0 of 1 sources checked- cites Choi, 2023 source
- Interpretationreasoning
Early implementation patterns reveal an important tension between the need for coordinated AI oversight and the practical advantages of distributed regulatory responsibility.
“These early implementation patterns also reveal an important tension between the need for coordinated AI oversight and the practical advantages of distributed regulatory responsibility.”
Quote in the paperSubstantial claim - Interpretationreasoning
The predominant avoidance of the unified model by early implementing Member States indicates significant practical barriers, potentially including resource constraints, institutional path dependencies, and challenge in developing the multidimensional expertise necessary for comprehensive AI oversight within a single independent regulatory entity.
“The predominant avoidance of this model by early implementing Member States indicates significant practical barriers, potentially including resource constraints, institutional path dependencies, and challenge in developing the multidimensional expertise necessary for comprehensive AI oversight within a single independent regulatory entity.”
Quote in the paperSubstantial claim
- 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).
InterpretationcitationThis 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 givenWhile 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 claimMay combine two claims. The quote only partly states this claim.
FindingreasoningCyprus 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 dataLithuania 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 dataRegulatory 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 givenItaly 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).
FindingcitationIt 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.
FindingreasoningLuxembourg 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 givenHungary 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- Also stated in: § 6. Conclusion · plain
May combine two claims.
Findingown dataThe 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- Also stated in: § 6. Conclusion · plain
May combine two claims.
Findingown dataThe 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 claimProbably not a substantial claim: may not pass S3 (load-bearing).
Findingnone givenThe 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 claimMay combine two claims.
FindingreasoningLuxembourg'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 claimMay combine two claims.
InterpretationreasoningPoland 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 claimProbably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.
InterpretationreasoningThe 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 claimMay combine two claims.
InterpretationreasoningPoland'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 claimProbably not a substantial claim: may not pass S2 (checkable), S4 (based).
Interpretationnone givenThese 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 claimProbably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.
InterpretationreasoningThe 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 claimProbably not a substantial claim: may not pass S2 (checkable), S3 (load-bearing), S4 (based).
InterpretationreasoningIt 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 claimMay combine two claims.
InterpretationreasoningWhile 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 claimMay combine two claims.
InterpretationcitationThe 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.
InterpretationcitationThe 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.
InterpretationreasoningHungary'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 claimMay combine two claims.
InterpretationreasoningNew 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 claimMay combine two claims.
InterpretationreasoningOrganizational 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 claimMay combine two claims.
InterpretationreasoningThese 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 claimProbably not a substantial claim: may not pass S2 (checkable), S3 (load-bearing), S4 (based). May combine two claims.
InterpretationreasoningThis 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 claimProbably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.
InterpretationcitationThe 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.
InterpretationreasoningBy 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 claimProbably not a substantial claim: may not pass S3 (load-bearing).
InterpretationreasoningBuilding 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).
InterpretationreasoningThe 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
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.”
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
MajorThe Luxembourg section names the Government Data Protection Commission as a notifying authority, whereas Table 1 names the National Commission for Data Protection.
“including the Luxembourg Institute for Standardization, Accreditation, Safety and Quality of Products and Services and the Government Data Protection Commission as notifying authorities.”
“Notifying authorities Luxembourg Institute for Standardization, Accreditation, Safety and Quality of Products and Services X National Commission for Data Protection X”
Fountain citation year differs from the reference
MinorThe text cites Fountain as a 2004 publication, but the corresponding reference lists 2001.
“(Fountain, 2004)”
“Fountain, J. E. (2001).”
Laux citation year differs from the reference
MinorThe text cites Laux as a 2024 publication, but the corresponding reference lists 2023.
“(Laux, 2024)”
“Laux, J., Wachter, S., Mittelstadt, B. (2023).”
Luxembourg's coordinating authority is identified differently
MinorThe 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.
“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.”
“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.”
Cites
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“This comprehensive expertise requirement reflects the complex and multidisciplinary nature of AI oversight (Dwivedi, 2021).”
Building the Virtual State: Information Technology and Institutional Change
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Governance of artificial intelligence
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“Their implementation strategy suggests a conception of AI oversight as fundamentally cross-cutting, requiring coordinated supervision that transcends traditional regulatory boundaries (Taeihagh, 2021).”
Ethical governance is essential to building trust in robotics and artificial intelligence systems
Winfield, A. F. T., & Jirotka, M. (2018) · Philosophical Transactions of the Royal Society A: Mathematical, Physical and Engineering Sciences · doi:10.1098/rsta.2018.0085 · Cited by 493 · cited 1× · see citing works
“This approach suggests a pragmatic strategy that capitalizes on established regulatory expertise and existing strong institutional frameworks (Winfield, 2018).”
A Layered Model for AI Governance
Gasser, U., & Almeida, V. A. F. (2017) · IEEE Internet Computing · doi:10.1109/mic.2017.4180835 · Cited by 431 · cited 2× · see citing works
“This highlights the need for robust oversight mechanisms to build public trust in AI technologies while guaranteeing a flexible and comprehensive regulatory framework to accommodate cultural differences and bridge gaps across different national legal systems (Gasser, 2017).”
Laux, J., Wachter, S., & Mittelstadt, B. (2024) · Regulation & Governance · doi:10.1111/rego.12512 · Cited by 365 · see citing works
Mikhaylov, S., Estève, M., & Campion, A. (2018) · Philosophical Transactions of the Royal Society A Mathematical Physical and Engineering Sciences · doi:10.1098/rsta.2017.0357 · Cited by 318 · cited 1× · see citing works
“This approach potentially leverages existing expertise across different domains – that requires developing a nuanced understanding of a highly complex policy landscape (Margetts, 2024) – but may face increased administrative complexity and coordination challenges (Mikhaylov, 2018).”
Implementing collaborative governance: models, experiences, and challenges
Bianchi, C., Nasi, G., & Rivenbark, W. C. (2021) · Public Management Review · doi:10.1080/14719037.2021.1878777 · Cited by 282 · see citing works
Feijóo, C., Kwon, Y., Bauer, J. M., Bohlin, E., Howell, B. E., Jain, R., Potgieter, P. H., Vu, K. M., Whalley, J., & Xia, J. W. (2020) · Telecommunications Policy · doi:10.1016/j.telpol.2020.101988 · Cited by 237 · cited 1× · see citing works
“Coordination complexity emerges as another significant challenge, particularly in cases where AI systems intersect with multiple regulatory domains (Feijo o, 2020).”
AI Governance in a Complex and Rapidly Changing Regulatory Landscape: A Global Perspective
Zaidan, E., & Ibrahim, I. A. (2024) · Humanities and Social Sciences Communications · doi:10.1057/s41599-024-03560-x · Cited by 237 · cited 1× · see citing works
“Member States must not only secure initial funding but also maintain and potentially increase resources as the AI landscape evolves and regulatory demands grow, a global tendency in AI governance worldwide (Zaidan, 2024).”
Responsible AI Pattern Catalogue: A Collection of Best Practices for AI Governance and Engineering
Lu, Q., Zhu, L., Xu, X., Whittle, J., Zowghi, D., & Jacquet, A. (2023) · ACM Computing Surveys · doi:10.1145/3626234 · Cited by 168 · cited 1× · see citing works
“The AI Act, which came into force in August 2024, sets the standard framework that European Member States must comply with to ensure that society understands AI’s capabilities and limitations, while promoting development and innovation (Lu, 2024).”
Organizing public sector AI adoption: Navigating between separation and integration
Selten, F., & Klievink, B. (2024) · Government Information Quarterly · doi:10.1016/j.giq.2023.101885 · Cited by 147 · cited 1× · see citing works
“…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).”
Opportunities, challenges, and benefits of AI innovation in government services: a review
Alhosani, K., & Alhashmi, S. M. (2024) · Discover Artificial Intelligence · doi:10.1007/s44163-024-00111-w · Cited by 132 · cited 1× · see citing works
“This granular approach stems from an understanding that AI systems pose distinct challenges depending on the application context (Alhosani, 2024), demanding tailored oversight mechanisms.”
The EU's AI act: A framework for collaborative governance
Cancela-Outeda, C. (2024) · Internet of Things · doi:10.1016/j.iot.2024.101291 · Cited by 129 · cited 2× · see citing works
“The AI Act also mandates the inclusion of diverse stakeholders in the governance scheme to ensure equitable representation and avoid potential biases (Cancela-Outeda, 2024).”
Laux, J., Wachter, S., & Mittelstadt, B. (2022) · Social Science Research Network · doi:10.2139/ssrn.4230294 · Cited by 99 · see citing works
A Robust Governance for the AI Act: AI Office, AI Board, Scientific Panel, and National Authorities
Novelli, C., Hacker, P., Morley, J., Trondal, J., & Floridi, L. (2024) · European Journal of Risk Regulation · doi:10.1017/err.2024.57 · Cited by 74 · cited 2× · see citing works
“Considering the insights already identified in the different patterns of AI national competent authorities (Novelli, 2024), the analysis employs a three-dimensional framework developed to systematically examine different implementation models.”
Trust, regulation, and human-in-the-loop AI: within the European region
Middleton, S. E., Letouzé, E., Hossaini, A., & Chapman, A. (2022) · Communications of the ACM · doi:10.1145/3511597 · Cited by 73 · cited 1× · see citing works
“…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).”
Institutional Collaboration and Competition in Artificial Intelligence
Shao, Z., Yuan, S., & Wang, Y. (2020) · IEEE Access · doi:10.1109/access.2020.2986383 · Cited by 38 · cited 1× · see citing works
“From an institutional theory perspective, it might pose challenges in terms of competition among institutions for resource allocation (Shao, 2020).”
Artificial Intelligence in the Public Sector
Wirtz, B. W., & Weyerer, J. C. (2019) · Springer eBooks · doi:10.1007/978-3-319-31816-5_3701-1 · Cited by 18 · cited 1× · see citing works
“Indeed, the expertise requirements pose a particularly complex challenge in the current technology labor market (Medaglia, 2024).”
The EU AI Act and the Wager on Trustworthy AI
Bellogín, A., Grau, O., Larsson, S., Schimpf, G., Sengupta, B., & Solmaz, G. (2024) · Communications of the ACM · doi:10.1145/3665322 · Cited by 18 · cited 1× · see citing works
“The latter is particularly driven by the complexity of the matter, which demands expertise from diverse fields as the technology evolves (Cancela-Outeda, 2024) with regulatory standards, addressing ethical concerns, and promoting transparency in AI decision-making (Bellogì n, 2024).”
To govern or be governed: an integrated framework for AI governance in the public sector
Choi, H., & Park, M. J. (2023) · Science and Public Policy · doi:10.1093/scipol/scad045 · Cited by 15 · cited 1× · see citing works
“However, this choice also reflects the complexity of AI governance, where different aspects of oversight may require distinct types of regulatory approaches and expertise (Choi, 2023).”
Educating AI developers to prevent harmful path dependency in AI resort-to-force decision making
Chiodo, M., Müller, D., & Sienknecht, M. (2024) · Australian Journal Of International Affairs · doi:10.1080/10357718.2024.2327366 · Cited by 15 · cited 1× · see citing works
“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.”
How to Build Progressive Public Services with Data Science and Artificial Intelligence
Margetts, H. Z., Dorobantu, C., & Bright, J. (2024) · Political quarterly (London. 1930. Print) · doi:10.1111/1467-923x.13448 · Cited by 6 · cited 1×
“This approach potentially leverages existing expertise across different domains – that requires developing a nuanced understanding of a highly complex policy landscape (Margetts, 2024) – but may face increased administrative complexity and coordination challenges (Mikhaylov, 2018).”
Competences and Governance Practices for Artificial Intelligence in the Public Sector
Medaglia, R., Mikalef, P., & Tangi, L. (2024) · CBS Research Portal (Copenhagen Business School) · doi:10.2760/7895569 · Cited by 6 · see citing works
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EU AI Act and the Rights-Based Approach to Technological Governance
Pavlidis, G. (2026) · Review of European and Comparative Law · doi:10.31743/recl.19283 · Cited by 3 · see citing works
Abbas, Z. A., Dahsh, Z. M., & Shpektorenko, I. (2026) · Communications in computer and information science · doi:10.1007/978-3-032-39720-1_1
- Authors
- Parisini, E., & Dervishaj, E.
- Affiliations
- University of Pisa (IT)
- Venue
- Conference on Digital Government Research
- Publisher
- TU Delft OPEN Publishing
- Published
- 2025-05-22
- ISSN
- 3050-8681 (ISSN-L)
- 1944-4907
- OpenAlex
- W4410587279
- Semantic Scholar
- d2442aa90c585875f1bad8329deac074e2c274d6
- Cited by
- 2
- References
- 22
- Citations by year
- 2026: 2
- FWCI
- 22.27
- Type
- conference paper
- Language
- en
- Open access
- diamond
- doi.org
- 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
About these checks
Registry, retraction, Cites and statistics results are computed, not judged, with one exception: a printed reference that no index lists is read once by a model before it counts as a citation error. Claims are extracted by a model and kept only when their quote appears verbatim in the text; each cited source is then checked, with a model’s help, for whether it says what the claim relies on. Those verdicts can be wrong — read the claim’s quote and the cited source before relying on one.
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