22 – Ρυθμιστικό Δοκιμαστήριο Τεχνητής Νοημοσύνης

ICPAC-GM has asked on this thread for a stakeholder advisory group with representation from professional bodies, transparent admission criteria, publication of non-confidential guidance, and sector-specific actions for accounting, audit and assurance services. That ask is well made and this comment asks for the same for education, on the same provision.

Article 22(1) makes the Commissioner, together with the Office of the Commissioner for Personal Data Protection, the national authorities responsible for the sandbox, so those are the two offices on which the following duties fall. Article 22(2)(b) requires the authorities to organise awareness-raising and training actions on the application of the Regulation, tailored to the needs of SMEs including start-ups, small mid-caps, deployers and, as appropriate, local public authorities. Article 22(2)(c) requires them to use and where appropriate establish channels with the same classes to give advice on the application of the Regulation.

Of those classes only one reaches a school. Education in Cyprus is centrally administered: municipalities and communities hold no competence in education, and the «Σχολικές Εφορείες», though local legal persons, have a statutory remit concerning school buildings, furnishings and equipment rather than the deployment of systems that evaluate learning outcomes. The local public authorities limb therefore does not reach the body that operates such a system. The deployer limb does, because a school running an AI system is a deployer within the meaning of article 3(4) of the Regulation, and deployers are separately listed in both (b) and (c).

That matters because of Article 4 of the Regulation, as amended by Regulation (EU) 2026/1744, which keeps the AI literacy duty with the deployer while requiring the Commission and the Member States to support deployers in meeting it. Article 22(2) is the instrument through which Cyprus discharges that support duty, and education is the sector where the deployer is least likely to be reached by any other limb.

One observation from the evidence, offered for what it is. Across seventeen national and system-level AI-in-education programmes reviewed by this practice, the strongest observed predictor of a programme surviving past its second year is whether teachers were prepared before pupils met the tools. Estonia prepared first and reports 94 per cent use among participating teachers. Korea deployed first in March 2025; adoption fell from 37 per cent in the first semester to 19 per cent in the second, and in August 2025 the National Assembly revoked the programme’s textbook status. Seventeen programmes is a small number with no counterfactual and no causal claim is made; the sequencing is an observation across them, and the two anchor cases are documented in opposite directions from named public sources.

Suggestion. Name education and vocational training expressly among the sectors served by article 22(2)(b) and (c), and provide that for that sector the training may take the form of a recognised teacher qualification, which discharges the deployer’s duty and the State’s support duty in one act and is measurable. This specifies how an existing duty is discharged; it does not purport to extend the list in article 62(1) of the Regulation, on which the chapeau to article 22(2) is conditioned. On that conditioning, a separate point: article 20 of this Bill enumerates the Union acts the Authorities are to take into account and omits article 62, although article 22(2) is expressly made subject to the conditions in articles 62 and 70(8). The enumeration should include article 62.

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.