24 – Δημόσιες Διαβουλεύσεις

The comment already on this thread asking for minimum notice, consultation and publication requirements, and for reasoned consideration of material submissions, is well made and this practice supports it rather than repeating it. What follows is why it carries more weight for one sector than the drafter may have supposed.

Article 24(2) obliges every Competent Authority to consult before issuing secondary legislation. For most sectors that duty sits alongside a designated sectoral authority: financial services have the Central Bank under article 5(1)(c), and Annex III point 1 so far as used for law enforcement, border management, justice and democracy, together with points 6, 7 and 8, has the Commissioner for Personal Data Protection under article 5(1)(b). Those sectors have a standing interlocutor whether or not a consultation is well run.

Education has none. Annex III point 3 is assigned to no sectoral authority, a question this practice has put on the article 5 thread. For that sector, article 24(2) is not one procedural guarantee among several. It is the only one. A consultation duty with no minimum notice, no publication requirement and no duty to give reasons is therefore weaker in this sector than anywhere else in the Bill, and the sector least able to notice that is the one whose deployers are schools.

Suggestion. Prescribe minimum notice and publication, and require a published reasoned response to material submissions, as the existing comment proposes. Provide in addition that where secondary legislation concerns an Annex III sector for which no sectoral Competent Authority has been designated, the Authority identifies and notifies the responsible ministry directly, so that the absence of a designated authority does not also mean the absence of a consulted one.

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.