Netherlands Opens Public Consultation on AI Act Implementation Law in April 2026

The Dutch State Secretary for Digital Economy and Sovereignty, Willemijn Aerdts, placed the draft Uitvoeringswet AI-verordening (Implementation Act for the EU AI Regulation) on public internet consultation on 20 April 2026. The consultation runs until 1 June 2026 via the central government portal at rijksoverheid.nl. The House of Representatives (Tweede Kamer) was simultaneously informed by letter of the government's proposed supervisory structure.

The controlling instrument is Regulation (EU) 2024/1689 of the European Parliament and of the Council (the EU AI Act), which entered into force on 2 August 2024. Article 70 et seq. of the AI Act requires each Member State to designate one or more national competent authorities for market surveillance and to notify the Commission. The Uitvoeringswet AI-verordening implements this obligation by assigning sector-based supervision, meaning existing regulators supervise AI within their own domain. Where no existing supervisor has jurisdiction, the Autoriteit Persoonsgegevens (Data Protection Authority) will act as AI supervisor, assisted by a designated AI Commissioner. The Autoriteit Persoonsgegevens and the Rijksinspectie Digitale Infrastructuur (Digital Infrastructure Inspectorate) will hold coordinating roles across the supervisory system.

Developers, deployers, and importers of AI systems in the Netherlands must identify their obligations under the AI Act's risk-based classification. Prohibited AI practices under Article 5 of the AI Act (such as manipulative subliminal techniques and mass scraping of facial images for biometric databases) already apply. High-risk AI systems listed in Annex III — including those used in employment, critical infrastructure, education, law enforcement, and healthcare — face requirements on data governance, risk management, human oversight, and transparency. Under the Dutch hybrid model, each market participant will primarily deal with the sectoral regulator they already know.

The draft law must still receive the Council of State advisory opinion (Raad van State) before submission to the Tweede Kamer for formal legislative treatment. No implementation deadline was specified in the consultation notice, but the consultation closes 1 June 2026. All entities operating AI systems in the Netherlands, including non-Dutch companies whose systems affect Dutch users, should monitor the final law as it will designate the competent supervisors responsible for enforcement.

Our firm advises on EU AI Act compliance, including risk classification, conformity assessment procedures, and regulatory mapping for AI systems deployed in EU member states. We maintain a dedicated partnership network covering the Netherlands, Belgium, and broader EU jurisdictions. Clients requiring guidance on the Dutch implementation consultation or the AI Act's market surveillance structure are invited to contact us. Relevant areas include AI governance, GDPR and AI Act intersection, high-risk AI system compliance, AI regulatory strategy, algorithmic auditing, and EU digital regulation.

Source: Digitale Overheid (Dutch Government Digital Affairs), "Consultatie Uitvoeringswet AI-verordening van start," published 21 April 2026, https://www.digitaleoverheid.nl/nieuws/consultatie-uitvoeringswet-ai-verordening-van-start/, confirmed 23 April 2026.

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