Wiki / EU AI Act / Member-state transposition
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EU AI Act — member-state transposition
Per-Member-State transposition tracker for EU AI Act. Status of EU Member-State implementing legislation across all 27 states, cross-linked to /wiki/regulators for the designated National Competent Authority (NCA) detail of each Member State. 5 of 27 Member States have populated rows as of 2026-06-01; the remaining 22render explicit “no public record located” rows so the editorial coverage gap is visible.
Status legend
Ordered low-to-high progression. “Litigated” breaks the gradient on purpose: a litigated row carries different semantic weight than a mere in-force row.
Transposition matrix
Rows = the 27 EU Member States; columns = key article- clusters in EU AI Act. Cells show the most-progressed status from each Member State's populated articles that overlap with the cluster, or “not yet” when no article overlap is recorded.
| Member State | Art. 5 (Prohibited) | Art. 16-26 (Provider/deployer) | Art. 28 (Notifying) | Art. 50-55 (GPAI + transparency) | Art. 57 (Sandbox) | Art. 70 (NCA) |
|---|---|---|---|---|---|---|
| ATAustria | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| BEBelgium | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| BGBulgaria | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| HRCroatia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| CYCyprus | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| CZCzechia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| DKDenmark | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| EEEstonia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| FIFinland | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| FRFrance | Not yet | Not yet | Not yet | Not yet | Not yet | Consulted |
| DEGermany | Not yet | Not yet | Drafted | Not yet | Not yet | Drafted |
| GRGreece | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| HUHungary | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| IEIreland | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| ITItaly | Not yet | Not yet | Not yet | Not yet | Not yet | Drafted |
| LVLatvia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| LTLithuania | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| LULuxembourg | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| MTMalta | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| NLNetherlands | Not yet | Not yet | Not yet | Not yet | Not yet | Drafted |
| PLPoland | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| PTPortugal | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| RORomania | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| SKSlovakia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| SISlovenia | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
| ESSpain | In force | Not yet | Not yet | Not yet | In force | In force |
| SESweden | Not yet | Not yet | Not yet | Not yet | Not yet | Not yet |
Status assigned via the rank-ordered most-progressed status of each Member State's populated articles that overlap the cluster's article references. Cells reading “Not yet” in a populated row mean the Member State has progress on other articles, just not this cluster.
Per-state detail
Expandable per-Member-State view with the populated articles and editorial notes. Only Member States with populated rows (status other than “not yet”) are expanded inline here.
ESSpain(España)In forceupdated 2026-06-01
Articles addressed
- Art. 70 (NCA designation)
- Art. 57 (Regulatory sandboxes)
Editorial note
Spain is the EU's first-mover on AI Act institutional preparation. AESIA (Agencia Española de Supervisión de la IA) constituted via Royal Decree 729/2023 (Aug 2023) as Spain's Art. 70 National Competent Authority — formally operational 2024. Spain ran an EU-AIA regulatory sandbox programme ahead of the formal Art. 57 timeline as a pilot for the broader European framework. The substantive transposition statute is still being drafted; the institutional layer is the in-force component.
FRFrance(France)Consultedupdated 2026-06-01
Articles addressed
- Art. 70 (NCA designation)
Editorial note
France's transposition is being co-led by CNIL (data-protection axis) and the Direction Générale des Entreprises (DGE) at the Ministère de l'Économie (industrial-policy axis). CNIL ran an 'AI Action Plan' consultation 2023-2024 covering its expected co-designation as a national authority. The full Art. 70 designation statute is in public consultation as of 2026; final adoption timing uncertain.
DEGermany(Deutschland)Draftedupdated 2026-06-01
Articles addressed
- Art. 70 (NCA designation)
- Art. 28 (Notifying authority)
Editorial note
Germany's transposition is structurally complex due to the Bundesländer division of competencies. The federal-level draft (BMWK lead, with co-leads from BMI + BMJ + BfDI) expects co-designation of BfDI and the Bundesnetzagentur as Art. 70 + Art. 28 authorities respectively. Public draft circulated mid-2025; Bundesrat-Bundestag passage pending. Some Länder (Bavaria, Baden-Württemberg) have signalled separate state-level NCA arrangements.
ITItaly(Italia)Draftedupdated 2026-06-01
Articles addressed
- Art. 70 (NCA designation)
Editorial note
Italy's transposition is being handled via a dedicated AI-bill (DDL Intelligenza Artificiale) introduced in the Senate 2024, separate from the Garante's existing GDPR-based jurisdiction. The bill names AgID (Agenzia per l'Italia Digitale) and the Agenzia per la Cybersicurezza Nazionale as co-designated authorities. The Garante's ChatGPT enforcement precedent (Dec 2024) is the most cited national-court interpretation under any AI-adjacent regime. Bill in parliamentary committee as of 2026-06.
NLNetherlands(Nederland)Draftedupdated 2026-06-01
Articles addressed
- Art. 70 (NCA designation)
Editorial note
The Netherlands is expected to co-designate the Autoriteit Persoonsgegevens (AP, the data-protection authority) and the Rijksinspectie Digitale Infrastructuur (RDI) as Art. 70 authorities, with sectoral overlays via the AFM (financial) and IGJ (healthcare). Draft statute circulated for public consultation late 2025; adoption timing uncertain. The AP issued substantive 'AI guidance' framing in 2024-2025 anticipating the formal designation.
What this tracker is — and is not
Editorial scope disclosure
Member-state transposition is a developing area. Coverage focuses on Member States with public progress; absence of a populated row means “no public record located” and NOT “no action taken”. Editorial tracking runs through ENISA + national-gazette publications + the European Commission's Better-Regulation Toolbox-#15 progress reports + each Member State's designated NCA publication channels.
For binding interpretation of any Member State's transposition status, consult the official national gazette and the responsible NCA's own publication. Policy Window claims editorial faithfulness to the primary source, not legal authority over it.