Greece Makes the First Step in Implementation of the AI Act
Greece Makes the First Step in Implementation of the AI Act
November 2024
Irene Kyriakides, Partner, Natalia Soulia, Senior Associate, Terpsithea Papanikolaou, Junior Associate
Kyriakides Georgopoulos Law Firm
The Greek AI governance framework is being gradually shaped.
Pursuant to Article 77 (2) of Regulation 2024/1689 (AI Act) the Ministry of Digital Governance published today the list of the national authorities and bodies designated to supervise or enforce the respect for fundamental rights, including the right to non-discrimination, in relation to the high-risk AI systems used for the following purposes:
- biometrics;
- law enforcement;
- migration, asylum and border control management;
- critical infrastructure;
- education and vocational training;
- employment, workers’ management and access to self-employment;
- access to and enjoyment of essential private and public services and benefits; and
- administration of justice and democratic processes.
These authorities are the following:
- The Hellenic Data Protection Authority (in Greek ΑΠΔΠΧ);
- The Greek Ombudsman (in Greek Συνήγορος του Πολίτη);
- The Hellenic Authority for Communication Security and Privacy (in Greek ΑΔΑΕ); and
- The National Commission for Human Rights (in Greek EEΔΑ).
The listed authorities will be endowed with powers such as requesting access to any documentation produced or retained by AI system operators to demonstrate compliance with the AI Act, as needed to effectively fulfill their responsibilities within their mandate.
They may also address a reasoned request to the market surveillance authority (see below for further information) in order to organize the testing of a high-risk AI system through technical means in cases where documentation provided by AI system operators is not sufficient for determining potential infringement of fundamental rights.
These powers will take effect on August 2nd, 2026. The list has been submitted to the European Commission and will be revised if required.
The next step in the implementation of the AI governance framework, according to Article 70 of the AI Act, will be the establishment of at least one notifying authority and one market surveillance authority (collectively referred to as “national competent authorities”) for the overall supervision and enforcement of the AI Act on a national level until August 2nd, 2025, which will be cooperating with the authorities announced today. The national competent authorities are distinct from the abovementioned authorities that ensure respect observance of fundamental rights. The exact scope of their tasks will be determined by the Greek State, but in general they include the following:
- The notifying authority/ies will be responsible for setting up and carrying out the necessary procedures for the assessment, designation and monitoring of bodies that perform third-party conformity assessment activities (conformity assessment bodies), including testing, certification and inspection of whether certain high-risk AI systems comply with specific requirements set forth by the AI Act;
- The market surveillance authority/ies shall undertake activities and take measures to ensure that only products compliant with the AI Act and potentially other EU and national legislation, are made available on the EU market.
November 2024
Irene Kyriakides, Partner, Natalia Soulia, Senior Associate, Terpsithea Papanikolaou, Junior Associate
Kyriakides Georgopoulos Law Firm
The Greek AI governance framework is being gradually shaped.
Pursuant to Article 77 (2) of Regulation 2024/1689 (AI Act) the Ministry of Digital Governance published today the list of the national authorities and bodies designated to supervise or enforce the respect for fundamental rights, including the right to non-discrimination, in relation to the high-risk AI systems used for the following purposes:
- biometrics;
- law enforcement;
- migration, asylum and border control management;
- critical infrastructure;
- education and vocational training;
- employment, workers’ management and access to self-employment;
- access to and enjoyment of essential private and public services and benefits; and
- administration of justice and democratic processes.
These authorities are the following:
- The Hellenic Data Protection Authority (in Greek ΑΠΔΠΧ);
- The Greek Ombudsman (in Greek Συνήγορος του Πολίτη);
- The Hellenic Authority for Communication Security and Privacy (in Greek ΑΔΑΕ); and
- The National Commission for Human Rights (in Greek EEΔΑ).
The listed authorities will be endowed with powers such as requesting access to any documentation produced or retained by AI system operators to demonstrate compliance with the AI Act, as needed to effectively fulfill their responsibilities within their mandate.
They may also address a reasoned request to the market surveillance authority (see below for further information) in order to organize the testing of a high-risk AI system through technical means in cases where documentation provided by AI system operators is not sufficient for determining potential infringement of fundamental rights.
These powers will take effect on August 2nd, 2026. The list has been submitted to the European Commission and will be revised if required.
The next step in the implementation of the AI governance framework, according to Article 70 of the AI Act, will be the establishment of at least one notifying authority and one market surveillance authority (collectively referred to as “national competent authorities”) for the overall supervision and enforcement of the AI Act on a national level until August 2nd, 2025, which will be cooperating with the authorities announced today. The national competent authorities are distinct from the abovementioned authorities that ensure respect observance of fundamental rights. The exact scope of their tasks will be determined by the Greek State, but in general they include the following:
- The notifying authority/ies will be responsible for setting up and carrying out the necessary procedures for the assessment, designation and monitoring of bodies that perform third-party conformity assessment activities (conformity assessment bodies), including testing, certification and inspection of whether certain high-risk AI systems comply with specific requirements set forth by the AI Act;
- The market surveillance authority/ies shall undertake activities and take measures to ensure that only products compliant with the AI Act and potentially other EU and national legislation, are made available on the EU market.
