04 – Τροποποίηση του Άρθρου 14 του Βασικού Νόμου

Article 4 amends article 14 of the base Law, on payments from the Fund of the Office of the Commissioner, by adding to paragraph (b) the words including the Directorate for the Regulation of Artificial Intelligence. Article 5 of this Bill separately admits the Directorate to the annual budget under article 153.

Those are the two halves of one question. Article 5 sets what may be budgeted; article 4 sets what may be paid. The Directorate is admitted to both alongside everything else the Fund carries, with no separate identification at either point, so the amount actually spent on artificial intelligence regulation will not be visible in the accounts even after it has been spent.

The Fund’s income side compounds this. Article 15 of the Artificial Intelligence Law 2026 makes administrative fines collected by a Competent Authority revenue of that Authority’s own fund. So the Fund from which the Directorate is paid is also the Fund into which the Directorate’s fines are received, and neither flow is separately identified. Whatever view is taken of the incentive question raised on the article 15 thread, the accounting question is prior to it: at present neither the spending nor the receipts can be seen.

Suggestion. Provide that payments made in respect of the Directorate, and fines received in respect of its functions, are identified separately in the accounts of the Fund. This asks for no ring-fence and no minimum and constrains no discretion in any year. It makes both figures visible after the fact, which is the least that allows anyone to judge whether the resourcing promised in article 5(4) of the Artificial Intelligence Law 2026 is being delivered, and whether enforcement revenue is material to it.

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.