What the AI Act requires from the public sector
The AI Act defines categories of high-risk AI systems, which include most public-sector AI applications — decision-making on the granting of social assistance, procurement evaluation, personal data processing, and critical infrastructure management. These systems are required to have:
- a documented risk management system;
- oversight and quality control of training data;
- technical documentation and registration in the EU database;
- human oversight at all critical decision-making stages;
- cybersecurity measures and incident registration.
These requirements cannot be met simply by purchasing an AI product. They require a process, a structure and a system of accountability — which the PPP model can provide in a structured way.
PPP as a compliance mechanism
A well-structured PPP contract in the field of digitalisation can directly integrate AI Act compliance requirements: the private partner takes responsibility for the AI system's technical documentation and registration; the contract defines human oversight duties and the accountability structure; the SLA includes audit rights over AI performance for the state party; and data processing provisions ensure compliance with both the GDPR and the AI Act simultaneously. As a result, the state institution obtains not only an AI solution, but also a legally compliant framework for its operation.
Estonia's strategic position
Estonia has not treated the AI Act as an obstacle. The national AI and Data White Paper for 2024–2030 directly provides for the integration of AI Act requirements into public procurement procedures and compliance certification schemes, which in parallel serve as a quality standard for PPP projects. This approach allows Estonia to build exportable state AI solutions — because compliance with EU regulation also means usability in other EU Member States.
Latvia's opportunity
The AI Act will come fully into force in August 2026. Latvian public institutions have time, starting now, to structure AI implementation projects in a format that ensures compliance from the outset — rather than as a retrospective correction. PPP is the mechanism that makes this possible, while at the same time reducing the public sector's financial and technological risk.
PPPA invites participation in a dialogue on integrating AI Act requirements into the structure of PPP projects.