On 16 September 2025, the Department of Enterprise, Tourism and Employment announced the designation of fifteen national competent authorities under the EU Artificial Intelligence (“AI”) Act, and the creation of a National AI Office (“NAIO”) to act as the central coordinating authority. This distributed model builds on Ireland’s strong regulatory foundations and reflects the country’s commitment to responsible innovation and ethical AI adoption. It further positions Ireland at the forefront for AI regulation in Europe, and one of the first six Member States to reach the critical milestone of designating the competent authorities responsible for enforcement of the AI Act.
Key Regulatory Designations under Article 70
Article 70 of the AI Act requires each EU Member State to establish or designate at least one notifying authority and at least one market surveillance authority for AI oversight. On 5 March 2025, the government announced the designation of eight competent authorities. This decision was subsequently given legal effect via Statutory Instrument No. 366/2025 on 29 July 2025. S.I. 366/2025 also appoints the Minister for Enterprise, Trade and Employment (“the Minister”) as a national competent authority and a Single Point of Contact. The Minister will streamline coordination between the various Irish regulators, the European Commission, and stakeholders for the AI Act, pending the formal establishment of the NAIO through primary legislation.
The competent authorities will be responsible for implementing and enforcing the AI Act within their respective sectors. It is hoped that the decision to use the existing national framework of well-established sectoral authorities for enforcement, will make compliance with the AI Act easier for businesses.
Designated Competent National Authorities Under S.I. 336/2025
The Irish Government, via S.I. 336/2025, officially appointed the following bodies as national competent authorities:
- Central Bank of Ireland;
- Data Protection Commission;
- Health and Safety Authority;
- Health Products Regulatory Authority (“HPRA”);
- Marine Survey Office of the Department of Transport;
- Competition and Consumer Protection Commission (“CCPC”);
- Commission for Communications Regulation (“ComReg”);
- Commission for Railway Regulation;
- Minister for Enterprise, Tourism and Employment; and
- Minister for Transport.
Additional Competent Authorities
More recently, on 16 September 2025, the government announced that the following additional bodies would act as national competent authorities:
- Coimisiún na Meán;
- Commission for Regulation of Utilities;
- Health Services Executive;
- National Transport Authority; and
- Workplace Relations Commission.
The Government has indicated that it is working on an amendment to S.I. 366/2025 to officially designate these additional national competent authorities for the purposes of the AI Act.
Establishment of the NAIO
The Government’s Legislation Programme for Autumn 2025 confirms that the heads of a Regulation of Artificial Intelligence Bill and Non-Personal Data Bill (“the Bill”) are currently being drafted. The Bill will establish the new NAIO as an independent statutory entity. The government have indicated that the NAIO will have four key functions, including to:
- co-ordinate Competent Authority activities to ensure consistent implementation of the EU AI Act;
- serve as the single point of contact for the EU AI Act;
- facilitate centralised access to technical expertise by the other competent authorities, as required; and
- drive AI innovation and adoption through the hosting of a regulatory sandbox, and act as a focal point for AI in Ireland, encompassing regulation, innovation and deployment.
The Bill will also likely provide for information sharing across the national competent authorities, empower those authorities to enforce the AI Act, and lay down penalties for non-compliance. The Government has indicated that the target date for publication of this Bill is Quarter 1 2026, with the expectation that it will be enacted by 2 August 2026.
Enforcement
In the absence of any enforcement measures at national level, there is some uncertainty as to whether the national competent authorities appointed to date will be able to enforce the AI Act. Article 99 of the AI Act only requires Member States to lay down the rules on penalties and other enforcement measures (including warnings and non-monetary penalties) by 2 August 2025, and does not directly provide national regulators with powers to enforce these penalties.
Therefore, we may not see any enforcement action taken in respect of compliance with the AI Act until after 2 August 2026 (i.e. when the Bill comes into force). However, civil action may be taken against organisations in the interim in respect of those provisions of the AI Act that have come into force to date, such as in respect of prohibited AI practices. The 2 August 2026 is also the date for the commencement of most of the remaining provisions of the AI Act, including the provisions enabling enforcement of obligations for providers of General Purpose AI models by the EU AI Office. In the interim, organisations developing or deploying AI also need to be mindful of their obligations under other related legislation, such as the GDPR, particularly if they are using personal data to train AI models.
Our Comprehensive Guide for Businesses to the EU AI Act
To help you understand your organisation’s obligations under the EU AI Act, we have published a comprehensive EU AI Act Guide for Businesses which summarises key aspects of the Act.
To access the Guide, click here.
Contact Us
Matheson’s Digital Economy Group, are available to guide you through the complexities of navigating compliance with the AI Act and building your AI governance framework. For more information, please contact Davinia Brennan, Sarah Jayne Hanna, Anne-Marie Bohan, Deirdre Crowley or Alice Duffy or your usual Matheson contact.