If you are unsure who is implementing and enforcing the new digital law and what the specific time frames are, you might find this as well as my next article very helpful. The attached document to this one gives you on 25 pages a comprehensive list of all obligations and tasks that the AI Act refers to the European Commission.
Since the technical negotiations on the AI Act have been concluded in January 2024, I hear very different numbers and deadlines when it comes to secondary legislation but also other implementing and enforcement tasks for the EU and national level. The Commission, for instance, stated on panels that they have to draft around 70 implementing and delegated acts. A At the same time, many external stakeholders mentioned contradicting deadlines for templates and guidelines.
One of the objectives of my blog is to make EU laws more accessible and EU policy less opaque. This is why I spent the last two weeks reading the AI Act (+ the Decision to establish an AI Office), while looking for the obligations that the law gives the Commission as well as for the respective time frames to fulfil those tasks. The result: the estimates mentioned above are not so far off. The slow buildup of the AI Office and its bureaucratic procedures will make it moreover very hard to meet the tight deadlines stated in the AI Act.
In total, I have identified 130 responsibilities for the Commission:
39 tasks with the aim to establish an AI governance system, to be executed between 21 February 2024 until 02 August 2026.
39 pieces of secondary legislation, which can be divided into 8 Delegated Acts, 9 Implementing Acts, 9 guidelines, 8 templates / benchmarks, 2 Codes of Practice, 2 categories of Codes of Conducts, and 1 standardization request. Some of them feature clear deadlines, others depend on the Commission's discretion.
34 different categories of enforcement activities on EU level, some of them will start on 2 February 2025.
18 tasks with the aim to conduct ex-post evaluation of the law, to be executed between 2025 and 2031.
I hope that this list is helping in particular civil society, academics, and SMEs that do not have the necessary resources to monitor the whole implementation and enforcement of the AI Act on EU level. My table should allow them to identify their key priorities and to focus their scrutiny activities with regard to the European Commission to those areas.
You can download the document here:
P.S.: Please let me you know if you find any mistakes. I have triple-checked every item on the list but - due to the complexity of this project - I might have overlooked something. The document will be updated regularly.
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