This position paper provides an overview of the Team-NB perspective on the challenges of the AI Act with particular attention to its implementation.
Because of the tight timelines for implementation, we welcome a coordinated approach between member states for the designation and oversight of NBs, being currently under discussion. The proposed pathway referring to Article 43(3) and making use of the existing software-related codes to include AI Act requirements enables notified bodies to assess MDAI in an efficient manner without compromising due scrutiny. Although Article 30 foresees designation of AI NBs in a horizontal manner (i.e. across different business areas), this pathway may be too time consuming and complicated to establish enough NBs for MDAI to meet industry demands in a timely manner. However, we observe with some concern that not all member states might be ready on 02 August 2025 with established
national implementing laws and designating authorities. Delays are likely to cause a shortage of designated NBs, when the high-risk scope of the AI Act becomes applicable on 02 August 2027…
