The new European AI Act (Artificial Intelligence) affects all public authorities, including water authorities and provinces, as outlined in the Impact Analysis for Water Authorities and Provinces. The report outlines the necessary actions for these organisations and key considerations for the responsible use and implementation of AI.
This analysis builds on an earlier impact assessment carried out for local authorities by the Association of Netherlands Municipalities (VNG).
User or provider: shared responsibilities
Provinces and water authorities generally act as users of AI systems, rather than providers. Nevertheless, they are still subject to the requirements of the AI Act. These include obligations such as employee training, oversight, incident reporting, and assessing fundamental rights when using high-risk AI systems.
Although providers carry the heaviest regulatory burden, users also have clear responsibilities; they cannot simply adopt a passive role.
Organisational changes required
The AI Act calls for organisational adjustments. These include conducting risk assessments, setting up monitoring and logging systems, and strengthening internal controls. Procurement processes will also need to be adapted.
While these changes may initially seem like additional work, they offer opportunities to embed responsible innovation. The Act supports the ethical and safe use of AI. In this process, cooperation between authorities is crucial, as shared knowledge and joint implementation can strengthen outcomes across the board.
Follow-up research underway
This impact analysis is part of the Local Authorities Feasibility Test (Uitvoerings- en Doelmatigheidstoets, UDO), which is assessing how feasible it is to implement the AI Act in collaboration with local authorities. The broader study is examining the consequences of implementation, including organisational impact and costs. This work is still ongoing and will conclude in 2026.
The complete analysis is available at Rijksoverheid.nl (in Dutch). You can also read the Performance Analysis Digital Decade AI-Act of the VNG (in Dutch).
