The EU AI Act is a Regulation, so it applies directly across the Union, but its day-to-day enforcement is national. Article 70 hands each Member State the job of naming the authorities that supervise AI systems and oversee the bodies that certify them, and Article 99 hands them the job of setting the penalties that give the Regulation teeth in their jurisdiction. Where a Member State has done neither, the obligations still bind, but the machinery that enforces them locally is not yet in place. This tracker records who has built that machinery and who has not.
The two authority types, and what each one does
Article 70 requires each Member State to designate, as national competent authorities, at least one of two kinds of body. They do different jobs, and it matters which one you are dealing with.
- Market surveillance authority. The supervisor and enforcer. It watches systems on the market, handles complaints, investigates, and can restrict, withdraw or recall a non-compliant system. For a provider or deployer, this is the authority that acts. Art 70, Art 74
- Notifying authority. The body that sets up and oversees the conformity-assessment bodies, the notified bodies that assess certain high-risk systems before they reach the market. It sits on the certification side rather than the enforcement side. Art 28, Art 70
A Member State can place both functions in one body or split them, and it can route different sectors to different regulators. For high-risk AI used by regulated financial institutions, for instance, the market surveillance authority is the existing financial supervisor rather than a general AI regulator, a point that also shapes credit scoring and insurance systems. General-purpose AI models sit outside this structure entirely: their obligations are enforced by the AI Office at Union level under Article 88.
The Article 70 deadline, and who missed it
The date to hold in mind is 2 August 2025. By then, under Article 70, each Member State had to have designated its notifying and market surveillance authorities and made their identity and contact details public. The same date, under Article 99(1), applied to adopting national penalty rules and notifying the Commission of them. Both deadlines have passed.
Compliance has been uneven. Some Member States moved early: Spain, for example, established a dedicated supervisory agency, AESIA, by national decree well ahead of the deadline. Others named existing regulators, split the role across several bodies, or had not published a settled designation when the date arrived. That unevenness is not a footnote. It changes where, and how quickly, a system in your estate can actually be challenged, and it is the reason a per-Member-State view is worth keeping.
The tracker
Every one of the 27 Member States has a row, so the gaps are as visible as the designations. Sort by any column: penalty regime to group by enforcement readiness, Member State to find a jurisdiction, or Last verified to see what has been confirmed most recently. A row with no source has not been verified against a primary page and is marked accordingly, rather than filled with a guess.
| Source | |||||
|---|---|---|---|---|---|
| Austria | Unverified | ||||
| Belgium | Unverified | ||||
| Bulgaria | Unverified | ||||
| Croatia | Unverified | ||||
| Cyprus | Unverified | ||||
| Czechia | Unverified | ||||
| Denmark | Unverified | ||||
| Estonia | Unverified | ||||
| Finland | Unverified | ||||
| France | Unverified | ||||
| Germany | Unverified | ||||
| Greece | Unverified | ||||
| Hungary | Unverified | ||||
| Ireland | Unverified | ||||
| Italy | Unverified | ||||
| Latvia | Unverified | ||||
| Lithuania | Unverified | ||||
| Luxembourg | Unverified | ||||
| Malta | Unverified | ||||
| Netherlands | Unverified | ||||
| Poland | Unverified | ||||
| Portugal | Unverified | ||||
| Romania | Unverified | ||||
| Slovakia | Unverified | ||||
| Slovenia | Unverified | ||||
| Spain | Agencia Española de Supervisión de la IA (AESIA) | Unverified | Source ↗ | ||
| Sweden | Unverified |
Read an unverified row as “not yet confirmed”, not as “none”. An empty authority field means we have not confirmed a designation against an official source at the last check, which frequently coincides with a Member State that has not published a clear one. If you need the position for a specific country for a filing or an opinion, follow the source link and confirm it directly, and tell us if you find an official designation we are missing.
National penalty regimes under Article 99
The headline penalty numbers belong to the Regulation, but the power to impose them is national. Article 99(1) requires Member States to lay down the rules on penalties and other enforcement measures and to ensure they are properly implemented, within the ceilings the Regulation fixes: the higher of 35,000,000 EUR or 7 percent of total worldwide annual turnover for prohibited practices, 15,000,000 EUR or 3 percent for most other breaches including the high-risk and Article 50 duties, and 7,500,000 EUR or 1 percent for supplying incorrect information. The full tier structure is set out on the penalties and enforcement page.
What varies by Member State is whether those national rules exist yet, and the tracker's penalty-regime badge records that: adopted, in draft, none, or unverified. Where a national regime is not in force, imposing a fine domestically can be delayed, but the substantive obligations still apply and a market surveillance authority can still order a non-compliant system restricted or withdrawn. The tracker keeps every status unverified until it is confirmed against a primary source, so an absence of confirmation is never presented as a confirmed absence.
What a designation gap means for your exposure
It is tempting to read a missing national authority as breathing room. That is the wrong lesson. The obligations in the Regulation apply on their own timetable regardless of whether a Member State has named its authorities, and enforcement gaps close, often retroactively in effect, once designation and penalty rules catch up. A system that is non-compliant today is non-compliant when the authority is finally stood up, and the documentation you did or did not keep is judged from the date the duty applied, not the date the regulator arrived.
The practical exposure also does not depend only on your home Member State. If you place a system on the market or your output is used across the Union, you can face the market surveillance authority of any Member State where the system operates, which is part of why territorial scope and your role decide your exposure more than your letterhead does. The right posture is to be compliant against the application dates and to treat the designation tracker as intelligence about enforcement timing, not as a checklist of who can currently reach you.
How this tracker is sourced and kept honest
The value of a table like this is only as good as its sourcing, so the rules behind it are deliberately strict. A field is populated only from an official national authority page or a Commission or AI Office publication, never from a secondary summary. Anything not confirmed that way is marked unverified with no source, and the Last verified column shows the date a person last checked the row against its primary source. When a designation or penalty law is published or changed, the row is updated from the official source and the change is recorded in the site changelog. If you maintain or can point to an official designation that belongs here, that correction is welcome, and it is the fastest way to move a row from unverified to confirmed. To classify a specific system against these authorities, run it through the free triage classifier. The primary framework text is on EUR-Lex and the Commission's AI policy pages.