Regulatory Intermediaries and Chains – the Complex Process of Sensemaking for AI Act Implementation in Finland

Abstract

The European Union (EU) Artificial Intelligence (AI) Act entered into force in August 2024. It aims to address different risks involved with AI systems. The regulation not only concerns organizations providing or deploying AI systems, but it mandates EU Member States to comply with the AI Act and change national law, if necessary. Member States act in the role of a regulatory intermediary (RI) for the AI Act. We conducted an interpretive case study to understand how a working group tasked with Finland’s national-level AI Act implementation made sense of changes the AI Act required to the national law for designation of National Competent Authorities. We contribute to Information Systems research by shedding light on the institutional process leading to new national law, highlighting Member States' role as an RI in implementing the AI Act on a national-level and introducing the concept of a regulatory chain involving multiple RIs.