Saatja: "Meritähti Maisa (OM)" <
[email protected]>
Saaja:
[email protected], "Justiits- ja Digiministeerium" <
[email protected]>
Teema: Estonia's regulatory framework for ADM and AI within public authorities
Kuupäev: 2026-03-20 07:25
Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.
Dear recipient,
I am contacting you from the Finnish Ministry of Justice. I would be very
grateful if you could point me toward the right person in your Ministry.
We are currently conducting a preliminary study project on the use of AI in
administrative procedure (information on the study available in Finnish
<https://valtioneuvosto.fi/hanke?tunnus=OM063:00/2025> here). The aim is to
determine the legal conditions for using AI at different stages of the
procedure – from the initiation of a matter to the final decision.
As part of this study, we are carrying out a brief comparative legal
analysis on the regulation of AI in administrative procedures in various
European countries, including Estonia.
We have taken note of your
<https://eelnoud.valitsus.ee/main/mount/docList/d5f01f2e-07bb-47f7-9536-564c7c136b2b#KHIqFcM7>
legislative proposal on enabling automated decision-making (ADM) within
public authorities and would like to ask a few questions.
* According to the proposal, the new legislation would be technology
neutral. Algorithms may make discretionary decisions if the discretionary
factors are predetermined by standardized rules. The number of options must
be limited, and the system then selects the appropriate solution according
to its internal logic.
* Does this mean that the proposal would not permit the use of more
autonomous AI (i.e., more advanced than rule‑based AI and within the scope
of the AI act) in administrative procedures?
* How would you define "technology-neutrality" in the context of the
proposal?
* Would the scope of the proposed regulation apply only to the use of
automated decision‑making for the final formal administrative decision?
* If so, would the use of more advanced AI be permitted in other stages of
the administrative procedure, such as the initiation of a matter?
* Additionally, we would be interested to hear whether, in the context of
the project, you have considered the legal conditions for the use of more
autonomous AI, and whether any related preliminary work is currently
underway.
Thank you very much in advance for your time and assistance. Please do not
hesitate to contact me should you require any further information.
Best regards,
Maisa Meritähti
Specialist
Department for Democracy and Public Law
Ministry of Justice of Finland
Email: <mailto:
[email protected]>
[email protected]
Tel. +358 295150159
<http://www.oikeusministerio.fi/> www.oikeusministerio.fi
PL 23 | 00023 Valtioneuvosto
<https://valtioneuvosto.fi/> valtioneuvosto.fi