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Ireland’s new AI enforcement framework

On 31 July 2026, Ireland’s Regulation of Artificial Intelligence Act 2026 (the “Irish AI Act”) came into force to give further effect to the EU AI Act in Ireland. This briefing examines the key features of the Irish AI Act and its implications for organisations subject to the EU AI Act in Ireland.

16/09/2026

Briefing

The Irish AI Act is focused on the following:

Establishing the AI Office of Ireland (the “AI Office”) as Ireland’s independent central coordinating authority under the EU AI Act
Empowering certain designated national authorities (known as market surveillance authorities) to oversee compliance with the EU AI Act in Ireland and to cooperate with one another
Prescribing a regulatory enforcement and administrative fining regime in Ireland in respect of the EU AI Act
Providing for regulatory sandboxes to support AI innovation in line with AI regulatory requirements

Establishment of the AI Office of Ireland

The AI Office now acts as a dedicated statutory body for coordinating and generally overseeing AI regulation in Ireland. As part of this, the AI Office will act as Ireland’s single point of contact with the European Commission, the EU AI Office and other EU bodies in respect of AI regulation. Other important aspects of the AI Office’s role include:

Coordinating with market surveillance authorities (e.g. the Central Bank of Ireland and the Data Protection Commission) and facilitating cooperation between these authorities so as to help ensure consistency of AI supervision/regulation across different sectors in Ireland
Establishing and maintaining a national public AI register to support transparency of AI supervision in Ireland and record, amongst other things, serious incidents involving high-risk AI systems and all incidences of prohibited AI practices in Ireland
Promoting AI literacy and innovation in Ireland

AI oversight and compliance in Ireland

Ireland has opted for a distributed, sector-based supervision/enforcement model for AI whereby market surveillance authorities (“MSAs”) supervise and enforce compliance with the EU AI Act in their sectors. As part of this:

The Central Bank of Ireland is designated as an MSA and oversees compliance with the EU AI Act by entities providing regulated financial services
The Data Protection Commission is designated as an MSA and will supervise protection of fundamental rights relating to personal data in the context of the use of high-risk AI systems

To assist MSAs in fulfilling their oversight role, the Irish AI Act empowers them to seek access to documentation from providers of AI systems. MSAs are also able to request access to data on training and testing of AI systems from providers. The Irish AI Act also introduces a framework for complaints to be made to an MSA in respect of an alleged breach of the EU AI Act. As part of this, the MSA must conduct an initial assessment into the complaint and then dismiss or act on the complaint or alternatively transmit it to another MSA if appropriate. The MSA has grounds to dismiss the complaint where it is determined to be frivolous, vexatious, trivial or made in bad faith.

AI enforcement and administrative fines

The Irish AI Act enables MSAs to appoint authorised officers to enforce AI regulatory requirements in Ireland. The enforcement powers available to authorised officers under the Irish AI Act include:

Inspection powers such as the power to carry out unannounced on-site inspections and physical checks of products (including the power to acquire product samples and reverse engineer products)
Issuing a contravention notice where an authorised officer reasonably suspects an infringement of the EU AI Act
Issuing a prohibition notice where an authorised officer reasonably suspects a breach of Article 5 (prohibited AI practices) or that an AI system presents a risk to health or safety of persons or to fundamental rights
Seizing and disposing of AI products that appear to be unsafe to the authorised officer
Issuing a notice requiring removal of AI content where there is a serious risk and no other effective remedy. This may include removal of online content or restricting access through information society service providers.

Failure to comply with a contravention or prohibition notice or a notice for removal of content within the period specified, without reasonable excuse, is an offence under the Irish AI Act punishable by a fine, imprisonment, or both.

The Irish AI Act also outlines the administrative fines process to be deployed by the MSAs for non-compliance with the EU AI Act. The first step in this process involves an authorised officer serving a notice of suspected non-compliance on a person following investigation by the authorised officer into such non-compliance. Following issuance of this notice, the authorised officer may, with the relevant MSA’s consent, refer the matter to an independent adjudicator for adjudication. This adjudicator will be appointed by the AI Office and the adjudication may involve an oral hearing where disputes of fact cannot be resolved through written submissions.

The adjudicator’s finding will be made on the balance of probabilities and where the adjudicator finds that a breach of the AI Act has occurred, the adjudicator will include a finding as to the amount of the administrative fine that should be paid by the offending party. The MSA may elect to adopt or refuse to adopt the finding of the adjudicator. Where such finding is adopted by the MSA, this finding may be appealed to the High Court within 28 days of receipt of this finding. The MSA must also apply to the High Court to confirm the finding of the adjudicator in the absence of any appeal.

The quantum of fines that may be imposed is set out in the AI Act itself and is summarised below:

For non-compliance with Article 5 (prohibited AI practices), fines of up to €35 million, or 7% of total worldwide annual turnover for the preceding year, whichever is higher
For non-compliance with provisions relating to operators or notified bodies (other than those in Article 5 of the EU AI Act), fines of up to €15 million, or 3% of total worldwide annual turnover for the preceding year, whichever is higher
For supply of incorrect, incomplete or misleading information to notified bodies or national competent authorities in reply to a request, fines of up to €7.5 million, or 1% of total worldwide annual turnover for the preceding year, whichever is higher
In cases of a public sector body, fines of up to €1 million

Ireland’s AI Regulatory Sandbox

The AI Office’s website confirms that Ireland’s AI Regulatory Sandbox Programme is under development. The intention of this sandbox is to put in place a controlled environment that fosters innovation and facilitates the development lifecycle of innovative AI systems in a manner that aligns with regulatory requirements. The Irish AI Act also helpfully recognises that personal data lawfully collected for other purposes may be processed within a sandbox environment for development, training and testing of AI systems in a lawful manner.

What are the next steps for organisations using AI?

At this stage, many organisations’ compliance efforts in respect of the EU AI Act will be well-progressed and these efforts should now account for the Irish AI Act. In particular, organisations should be alive to the role of the AI Office and their MSA, as articulated in the Irish AI Act, and assess whether any adjustments are required to their relevant governance framework and policies/procedures in light of this. Organisations should also consider whether participation in the forthcoming regulatory sandbox would be of benefit.

For further information, please contact a member of our Technology and Innovation Group.