The Artificial Intelligence Act (AI Act) is the EU’s first comprehensive legislation on the use of AI. It entered into force on 1 August 2024 and will become applicable as of 2 August 2026, with certain exceptions (International AI Act Timeline).

Despite being a regulation, and thus directly applicable across the EU, the AI Act requires member states to adopt some measures at national level.

This Cullen International Benchmark tracks the progress in the national implementation of the AI Act across 18 EU countries, providing an overview of:

• the national laws proposed or adopted to implement the AI Act;
• the set-up of regulatory sandboxes;
• the designation of competent authorities and the establishment of a framework on penalties, which should have been finalised by 2 August 2025.

Cullen International found that only Denmark and Italy have a national AI law in place, while proposals for AI laws were tabled in Germany, Luxembourg, Poland, Slovakia and Spain.

Most of the surveyed countries have not yet designated national competent authorities (NCAs) to enforce the provisions of the AI Act. The majority of those which have proposed or designated market surveillance authorities, would implement a decentralised model, distributing enforcement tasks among several authorities. 

Poland and Spain have established new entities to supervise the application of the new AI rulebook.

For more information and access to the full benchmark, please click on “Access the full content” - or on “Request Access”, in case you are not subscribed to our European Digital Economy service.