On Feb. 2, 2025, the first obligations under the European AI Regulation will come into effect. Municipalities will then have to comply with general provisions, prohibitions and obligations around AI literacy. With an implementation analysis, VNG is investigating what the impact on municipal implementation will be.

Read the report implementation analysis Digital Decade AI Regulation
With the AI Regulation, the European Union aims to make artificial intelligence (AI) safe, transparent, and in line with fundamental rights and European values. To this end, rules have been drafted to provide a uniform framework for all EU Member States. The first obligations will take effect on Feb. 2, 2025. For the obligations specific to high-risk AI systems, municipalities have more preparation time. These come into effect on Aug. 2, 2026.
The AI regulation has an impact on municipalities. By answering the 4 questions below, municipalities can determine which obligations of the AI regulation apply to their municipality.
Is the system we use an AI system according to the definition in the regulation?
What risk category does this AI system fall into?
As a municipality, are we the provider or the user responsible?
What obligations apply on that basis?
The impact of the regulation depends on the role a municipality plays. Different (more onerous) obligations apply to providers than to a user responsible for an AI system. Municipalities will have to deal with new activities from the role of user responsible, such as: setting up AI compliance, inventorying AI systems and organizing AI literacy and human supervision.
In addition, the AI regulation brings specific obligations, such as the use of new tools (e.g., fundamental rights assessments and the EU database) and enhanced risk management in high-risk AI systems.
Municipalities are not yet sufficiently equipped to meet the obligations of the AI regulation. For example, awareness of the possibilities and risks of AI is still at the beginning and municipalities are dependent on software vendors for the inventory of AI systems. There is also a high degree of dependence on providers of the AI systems to meet the obligations as a user responsible party. It is important that awareness around AI within municipalities begins to increase in the coming year. This report includes desired follow-up actions and describes what municipalities can do now in preparation.
This is the 3rd report of the implementation analysis Digital Decade. With this implementation analysis VNG provides insight into the impact of European laws and regulations on municipal implementation. The studies focus on the relationship between the various laws. Any problems in implementation can thus be identified at an early stage and fed back to the government. In this way, we guarantee feasibility when translating EU legislation into national regulations and work towards recommendations for the integral implementation of Digital Decade legislation.
