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Greece Adopts AI Act National Implementation Law 5321/2026, 16 July 2026

The Hellenic Parliament adopted Law 5321/2026 on 16 July 2026, designating national competent authorities and establishing enforcement and sandboxing procedures under Regulation (EU) 2024/1689 (the EU AI Act). The Hellenic Data Protection Authority is the principal market surveillance authority for prohibited AI practices and most high-risk AI systems. Greece is among the first EU Member States to enact national implementation legislation under the AI Act.

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The Hellenic Parliament adopted Law 5321/2026 on 16 July 2026, published in Government Gazette A' No. 114 dated 20 July 2026. The law is titled Measures for the Implementation of Regulation (EU) 2024/1689 of the European Parliament and of the Council of June 13, 2024, on Artificial Intelligence. Greece is among the first EU Member States to enact national implementing legislation designating supervisory authorities, establishing enforcement procedures, and creating regulatory sandboxes under the AI Act. The law also amends Law 4961/2022.

Law 5321/2026 designates the Hellenic Data Protection Authority (HDPA) as the principal market surveillance authority for prohibited AI practices under Chapter II of Regulation (EU) 2024/1689, certain high-risk AI systems under Chapter III, and AI systems subject to transparency obligations under Article 50. The Hellenic Telecommunications and Post Commission (EETT) is designated as the national notifying authority under Article 28(1) of the AI Act. The law implements Articles 57 through 63 of the AI Act by establishing AI regulatory sandboxes, which permit controlled testing under real-world conditions with regulatory oversight.

AI providers, deployers, importers, and distributors placing high-risk AI systems on the Greek market or using them in Greece must comply with Chapter III obligations monitored by the HDPA. AI deployers using systems subject to Article 50 transparency obligations face HDPA oversight from 2 August 2026, when those provisions take effect across the EU. The law establishes criminal penalties for removing transparency labels from deepfake content and introduces a unified complaints mechanism for reporting potential violations.

Law 5321/2026 amends Law 4961/2022, which previously governed AI governance in Greece. The law does not address potential conflicts between the HDPA's AI Act supervisory role and its existing GDPR supervisory mandate. Eligibility criteria for AI regulatory sandbox participation will be set through secondary regulation. The interaction between sandbox protection and liability under the AI Liability Directive remains unaddressed in the text.

Licentium advises AI developers, deployers, and operators on AI Act compliance across EU jurisdictions, including market surveillance authority engagement, high-risk system classification analysis, and transparency obligation readiness. Contact us to discuss AI Act applicability or national implementation requirements in Greece or across the EU. Work we undertake includes AI Act readiness assessments, high-risk system classification, conformity assessment procedures, GPAI model documentation, and regulatory sandbox applications.

Source: Hellenic Special Secretariat for AI and Data Governance, Law 5321/2026 — National AI Act Implementation, Government Gazette A' No. 114, 20 July 2026

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