AI consultant in The Hague

The register focuses on algorithms with a significant impact, including high-risk AI systems. At a minimum, this includes algorithms that contribute to decisions about someone’s rights, such as a fine or a grant. Publication is not yet a legal requirement. The government announced plans to make it mandatory in 2022, but the law has not yet been passed.

The municipality of Den Haag, which uses an algorithm to predict how busy polling stations will be, lists algorithms that affect residents’ daily lives and adds descriptions twice a year. You can establish who keeps the register up to date through AI governance.

No. The European database under the AI Act lists high-risk systems, and a public authority using one of these systems records its own use there. From 2 December 2027, Article 26 provides that if a high-risk system is not listed, a public authority must not use it and must notify the provider. Separate rules apply to critical infrastructure.

According to its administrators, the Dutch register will continue to exist because it also includes simpler, lower-risk algorithms.

Annex III includes systems that public authorities use to assess whether someone is entitled to essential benefits or public services. Under the digital omnibus, the rules for these high-risk systems will not apply until 2 December 2027. Before using certain high-risk systems, a public authority must then carry out a fundamental rights impact assessment (FRIA).

The IAMA, published by BZK, was aligned with the FRIA in February 2026. Your legal adviser will determine which obligation applies to your system. We set out all the effective dates in AI Act in practice.

An employee who follows every recommendation is not really making a decision. In its guidance, the Autoriteit Persoonsgegevens identifies four factors: people, technology and design, process, and governance. That means allowing time to assess a case, providing an explanation for each recommendation and giving employees the authority to depart from it.

The municipality of Den Haag requires an employee to make the final decision whenever an algorithm involves personal data and has legal consequences. You can have the application record when caseworkers depart from a recommendation, so you can demonstrate this too. We include that in the design. It is how we put Responsible AI into practice.

Leaving out protected characteristics is not enough: a model can still discriminate through a proxy, such as a postcode. Compare how often the model selects someone in each group and how often that selection proves justified, and check whether the data is representative. To do this, you need information such as a person’s background, which you may process only to a limited extent under the GDPR.

BZK’s Algorithm Framework refers to the risk profiling assessment framework of the College voor de Rechten van de Mens. The Autoriteit Persoonsgegevens, based in Den Haag, wants its new AI supervision directorate to ensure that such tools are tested for discrimination and accuracy.

Start with the sources: a chatbot is only as good as the knowledge it can access. At PostNL, Dex answers employees’ questions so the service desk can focus on more complex issues. Since 2 August 2026, the transparency rules under the AI Act have applied: people speaking to a chatbot must be told that they are doing so no later than the start of the conversation.

Since April 2025, public authorities have had a government-wide position on the use of generative AI, along with guidance on responsible use.

The Algorithm Framework lists requirements in the specification and award criteria, agreements on data and artefacts, the right to an audit, and a data processing agreement if personal data is involved. Determine in advance whether the algorithm has a decisive influence on a decision about individuals.

Also specify in advance what logging and documentation you need to complete the register entry and the FRIA.

If the algorithm applies a fixed calculation rule set out in law or regulations that anyone can verify, good documentation and a register entry are enough. If your question concerns appeals, liability or the interpretation of a legal provision, it belongs with a legal adviser.

Municipalities still exploring where AI might be useful can start with a less involved AI workshop for municipalities.