Denmark Enacts First EU AI Act Implementation Law, May 2025

The Danish Parliament (Folketing) adopted Bill L 154 on May 8, 2025, by a vote of 109 to 0, enacting Denmark's Law No. 467 of May 14, 2025, on supplementary provisions to the regulation on artificial intelligence (Lov om supplerende bestemmelser til forordningen om kunstig intelligens). The law entered into force on August 2, 2025, in Denmark proper; it does not apply to the Faroe Islands or Greenland. This makes Denmark one of the first EU Member States to complete the designation of national competent authorities required under Article 70 of Regulation (EU) 2024/1689 (EU AI Act) before the August 2, 2025 deadline.

Law No. 467 of May 14, 2025 designates national competent authorities as follows, pursuant to Articles 28 and 70 of Regulation (EU) 2024/1689. The Agency for Digital Government (Digitaliseringsstyrelsen) serves as the notifying authority, one of the market surveillance authorities, and the single point of contact for communication with other Member State authorities and the European Commission. The Danish Data Protection Authority (Datatilsynet) and the Danish Court Administration (Domstolsstyrelsen) serve as additional market surveillance authorities. The law also sets out the competences, tasks, and organizational structure of these authorities and establishes criminal sanctions — financial penalties only — for infringements of the EU AI Act and of the national supplementary law itself, with a five-year limitation period for criminal liability.

Entities that develop, deploy, or distribute AI systems on the Danish market must now deal with up to three national competent authorities depending on the domain and nature of the AI system at issue. The Digitaliseringsstyrelsen acts as the general-purpose market surveillance authority and as the single administrative entry point for cross-border coordination under the EU AI Act. Organizations subject to the General Data Protection Regulation that also operate high-risk AI systems must account for concurrent Datatilsynet oversight capacity under the AI Act alongside existing GDPR obligations. The Domstolsstyrelsen has authority over AI systems deployed in the administration of justice.

The Danish governance structure does not include sector-specific supervisory authorities; it relies entirely on three existing central-government bodies. Parties subject to market surveillance by the Digitaliseringsstyrelsen, Datatilsynet, or Domstolsstyrelsen should treat AI Act compliance reviews as distinct regulatory processes from existing sector-specific obligations, though overlapping jurisdiction with GDPR supervisory work at Datatilsynet may create concurrent inspection risk. Penalties under Law No. 467 are criminal rather than administrative, which differs from the enforcement model anticipated in Article 101 of the EU AI Act at the EU level for national competent authority violations.

Our firm advises organizations operating in Denmark and across the EU on compliance with the EU AI Act and related national implementation laws, including authority designation, notified body procedures, high-risk AI system conformity assessments, data protection overlap analysis, and cross-border market surveillance coordination. We maintain a dedicated partner network to assist with Danish-language regulatory engagements and on-the-ground compliance work. Entities affected by Law No. 467 of May 14, 2025 are invited to contact us directly. Areas of work include: EU AI Act compliance, national competent authority engagement, high-risk AI system assessment, GDPR and AI Act overlap analysis, AI governance structuring, Danish AI regulatory law.

Source: Folketing, Bill L 154, 2024-25 session (Forslag til lov om supplerende bestemmelser til forordningen om kunstig intelligens), adopted May 8, 2025; enacted as Law No. 467 of May 14, 2025; legislative file at https://www.ft.dk/samling/20241/lovforslag/l154/index.htm; confirmed March 23, 2026.

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