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EU AI Act

What is the KI-MIG?

Short definition

The KI-MIG is Germany’s implementing act for the EU AI Act. It has applied since 29 July 2026 and designates the Federal Network Agency as the central market surveillance authority for AI, with special responsibilities such as BaFin for the financial sector.

The EU AI Act applies directly in all member states but leaves the organisation of supervision to them. Germany adopted the Act on Market Surveillance and Innovation Promotion of Artificial Intelligence for this purpose. It was signed on 22 July 2026, published in the Federal Law Gazette 2026 I No. 223 and has applied since 29 July 2026.

The Federal Network Agency as central supervisor

Under section 2(1) KI-MIG, the Federal Network Agency is the competent market surveillance authority for the AI Act unless the act provides otherwise. It supervises prohibited practices, high-risk AI and transparency duties, acts as notifying authority for conformity assessment bodies and runs a coordination and competence centre. For certain sensitive high-risk areas, an independent AI market surveillance chamber is set up within it.

Special responsibilities

Existing sector supervisors remain responsible in their areas. In the financial sector, BaFin supervises the use of AI by the companies it oversees. For AI in products already subject to product supervision, the authorities responsible there remain competent.

Complaints office, service desk and sandbox

The Federal Network Agency receives complaints about breaches of the AI Act. An AI service desk is intended to support SMEs and startups in particular with implementation questions, and the agency sets up at least one AI regulatory sandbox in which innovative systems can be tested under supervision.

What companies should conclude

The KI-MIG contains no new substantive duties; these are in the AI Act. It does, however, clarify who audits and where complaints go. Companies should keep their AI inventory current and document their role as provider or deployer. For Swiss companies offering AI in Germany, the Federal Network Agency is therefore the most likely supervisory contact.

Sources and references

Legal position as of October 2026. Not legal advice for an individual case.

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