Belgium: before choosing a door, know where it leads

An SME uses software to screen job applications. An employee challenges a rejection they do not understand. A municipality is preparing a decision-support tool. They all face the same question: whom should they contact? The answer depends less on the name of an authority than on what they need: an explanation, supervisory scrutiny or a decision they can challenge.

On 6 October 2026, before the House of Representatives’ Economy Committee, Minister Vanessa Matz stated: “Belgium has not yet made this formal designation.” She described two parallel initiatives, a federal law and a cooperation agreement with the federated entities, with a central role envisaged for the BIPT. That statement describes the position on that date. Readers should check the legislation in force when they read this article.[1]

On 15 October 2026, the BIPT opened a consultation on its draft strategic plan for 2027–2029, running until 6 November 2026 inclusive. The draft describes responsibilities relating to data markets and the supervision of AI systems as “in the process of being assigned”. A note states that the Institute will “very probably assume all or part of the responsibility”, but that “the final legislative texts on this subject have not yet been adopted”.[2]

On 20 October 2026, before the House of Representatives’ Social Affairs Committee, Minister David Clarinval announced that the bill intended to establish the AI Act governance framework would be introduced together with the minister responsible for digital affairs in the first half of 2027. This is the timetable announced in a provisional parliamentary report, not evidence that a law has been enacted or published. It supplements the account given on 6 October; it does not remove the need to check legislation adopted since then.[10]

Preparing is not the same as being empowered

The draft is right to prepare: capabilities, guidance for SMEs and an AI supervision laboratory. But a strategic plan cannot, by itself, confer the power to demand a document, impose a measure or levy a penalty. For the new responsibilities envisaged, those powers must rest on the legislation assigning them, without disregarding powers that already exist. The distinction protects everyone: businesses that need to understand their obligations, people seeking a remedy and officials who need to know the limits of their remit.

The opposite conclusion would be equally wrong. The absence of a designation on a particular date does not place AI use outside the law. Data protection, employment law and consumer law continue to apply, each with its own authorities.

Map the functions, then test the routes

My first proposal, drawn from the contribution I prepared for the consultation, is to publish a map of functions rather than a list of addresses. Who provides information? Who receives a report? Who investigates a complaint? Who decides? Each box would identify its legal basis and be updated when the legislation changes. A referral from one service to another would become understandable rather than feel like a closed door.

My second proposal is to give practical form, through real user journeys, to the BIPT’s ambition to be a ‘compass in the digital world’. The draft describes a guiding role, not a named software product. It also plans to examine the establishment of a digital economy assistance service in 2027–2029. The routes proposed here are our contribution to that discussion.[2] People should be able to describe their problem before knowing its legal classification. The route should then explain what the service contacted can do, which documents are useful and what happens next. An acknowledgment is not a decision; reporting a concern does not always open proceedings. Explaining this early prevents disappointed expectations.

These routes would benefit from testing before publication, with citizens, SMEs and people less comfortable with digital tools. The consultation is the right moment to discuss them.

The proposals in these four articles are the author’s own, drawn from the contribution he prepared for the BIPT consultation. They do not represent the Institute.