03 – Τροποποίηση του Άρθρου 2 του Βασικού Νόμου

Article 3 of this Bill amends article 2 of the base Law, and it is the new paragraph (ν) inserted into subsection (2) that establishes the Directorate for the Regulation of Artificial Intelligence, for the exercise of the Office’s functions as notifying authority, market surveillance authority and single point of contact under Regulation (EU) 2024/1689. That paragraph names those three roles and stops. It states no composition, no competences and no expertise.

Article 6 of the Artificial Intelligence Law 2026 is the obvious answer to that, and it does not meet it. Article 6 provides that the Commissioner is constituted and organised internally in accordance with the base Law, as amended or replaced. That is a cross-reference to general organisational provisions written before artificial intelligence was a regulated field and before Annex III existed. General organisational powers can create a unit. They cannot supply sectoral competence for supervisory heads that did not exist when they were drafted, and nothing in either Bill states what competence this unit must hold.

The question matters because of how supervision is distributed. Under article 5(1) of the Artificial Intelligence Law 2026, Annex III point 1 so far as used for law enforcement, border management, justice and democracy, together with points 6, 7 and 8, goes to the Commissioner for Personal Data Protection, and financial institutions supervised by the Central Bank go to the Central Bank. Annex III point 3, education and vocational training, is assigned to no sectoral authority. Whether it therefore falls to this Directorate is a question this practice has put on the article 5 thread rather than assumed, because the Bill does not say so in terms.

Annex III point 3 covers systems intended to determine access or admission or to assign natural persons to educational and vocational training institutions at all levels; to evaluate learning outcomes, including where those outcomes are used to steer the learning process; to assess the appropriate level of education that an individual will receive or will be able to access; and to monitor and detect prohibited behaviour of students during tests. If those systems are supervised from this Directorate, the point stands whichever way the article 5 question is answered.

Suggestion. Provide that the Directorate’s establishment includes, for each Annex III head it supervises, competence in that sector, and state that education and vocational training is among them if it is. Provide that the competences held are stated in the Office’s annual report, so that a cross-reference to the base Law is not doing work it cannot do.

Uncommon People Consulting is an independent practice working on the deliverability of national AI-in-education policy. On 27 August 2026 it made a submission to the consultation on the draft National AI Strategy 2032 carrying twelve numbered comments, and that record is public. We are an independent practice, not a candidate delivery vehicle, and we take no part in recurring delivery work; our interest is strategic work on ordinary commercial terms openly stated. That position is unchanged. This comment is filed on the evidence.