Argentina - Buenos Aires - AI Guidelines (4/2025)

Overview

Resolución 4/2025 approves an annex titled "Directrices de uso de Inteligencia Artificial Generativa en la Administración Pública de la Provincia de Buenos Aires" (approved 10 February 2025; published 14 February 2025). The annex is a guideline document prepared by the Dirección Provincial de Innovación Digital under the Subsecretaría de Gobierno Digital and articulates mandatory minimum rules for public agents interacting with generative AI systems (IAGen). The directive's core aims are to protect fundamental rights, preserve confidentiality and integrity of public-sector information, ensure human oversight of AI-assisted outputs, and promote training and impact assessment prior to institutional deployment. The official texts are available from the Province's normative repository and the Ministry’s communications page: Normas GBA — Resolución 4/2025 and the annex PDF containing the detailed guidelines: Annex — Directrices IAGen (PDF). These materials provide the operative provisions, prohibitions, and the institutional roles responsible for oversight, training and incident reporting.

Definitions

The annex provides a compact glossary specifying terms used throughout the guidelines. Key definitions include: "Agent (personal)" — any person under any employment or contractual modality interacting with IAGen for provincial public administration tasks; "IAGen" — generative artificial intelligence (notably large language models and systems capable of producing novel content in natural language, images, audio or video); "Anonymization" — technical processes that render personal data non-identifiable; "Evaluation of impact" — preventive analysis to identify and mitigate risks associated with a specific AI use-case; "Bias / encoded prejudice" — deviations or erroneous decisions from AI outputs that may negatively affect certain individuals or social groups. The document clarifies that the listed definitions are meant to guide application and interpretation across agencies and to align with existing provincial and national data-protection norms.

Governance and Institutional Framework

The Subsecretaría de Gobierno Digital acts as the coordinating authority for implementation, supported by the Dirección Provincial de Innovación Digital and the Dirección Provincial de Sistemas Informáticos y Tecnología. The annex references the legal basis, including provincial laws and decrees that establish the organizational competence of these units (see explanatory preamble in the resolution text). Operationally, user provisioning and approval must transit via the provincial electronic document management platform GDEBA; supervisory approval (a formal note via GDEBA) is required before an agent may access a chosen IAGen tool. The Dirección Provincial de Innovación Digital is assigned responsibility for proposing policies, training programs, assessment templates and participation in national/international forums on AI governance. Security incidents and suspected misuse must be reported to the Dirección Provincial de Sistemas Informáticos y Tecnología or other competent cybersecurity bodies. The Ministry’s communications materials and the province’s institutional pages provide contact routes and organizational listings: Ministry news — published guidelines and the Subsecretaría’s institutional pages: Subsecretaría de Gobierno Digital — Contact.

Key Focus Areas

The annex organizes obligations and prohibitions around several focus areas. Data protection and confidentiality: all information processed in the scope of provincial tasks is considered confidential — even when non-personal — and agents must avoid uploading confidential or sensitive data to third-party IAGen systems unless appropriate safeguards (including anonymization and legal bases) are in place. Human supervision and decision-making: IAGen outputs must be treated as drafts; users must not delegate final decisions on benefits allocation, accreditation, verification, investigations or any action that may negatively affect rights to an AI system alone. Transparency and documentation: where outputs materially affect public communication or are creative works produced by IAGen (images, audio, video, or documents where the AI is the primary creator), the product must carry an explicit notice identifying it as AI-generated. Security and misuse: introducing credentials, infrastructure details or any data that could compromise state security is strictly prohibited; suspected breaches must be reported immediately. Risk assessment and training: the annex mandates an evaluation of impact appropriate to the use scenario and continuous training to maintain literacy about IAGen limitations, including bias and reliability issues. Ethical conduct and prohibition of personal use: agents must use IAGen ethically and for institutional purposes only; personal uses are forbidden. The provincial directive frames these areas as non-exhaustive baseline obligations and encourages agencies to adopt further measures as needed.

Implementation Framework

Implementation depends on a combination of operational rules and administrative procedures. Access control: agents must register and use official institutional e-mail addresses; higher-level approval via GDEBA is required prior to onboarding any IAGen. Tool selection and configuration: where available, configurations that minimize data retention and limit telemetry should be chosen; providers’ privacy and retention policies must be reviewed before adoption. Impact assessment: an Evaluation of Impact is required according to the use-case risk level — the annex frames this as a preventive instrument to identify and mitigate privacy, bias, legal and operational risks. Oversight and review: agencies must ensure supervisory reviews of AI-generated outputs prior to official use. Incident response: reporting lines to the Dirección Provincial de Sistemas Informáticos y Tecnología are specified for information security incidents or suspected misuse. Training and awareness: the Dirección Provincial de Innovación Digital is encouraged to develop curricular content and run recurring capacity-building programs for public servants to understand both technical limitations and legal obligations. These implementation steps should align with the province’s broader digital modernization strategy and existing legal frameworks referenced in the resolution preamble.

Monitoring and Evaluation

The annex requires monitoring through supervisory review of outputs, incident reporting channels, and periodic review of tool configurations and privacy settings. Evaluation of impact instruments must be used to assess specific deployments and to determine required mitigations (technical, organizational, or process-based). The Dirección Provincial de Innovación Digital should collect usage metrics, incident statistics and training completion rates to inform policy updates. Agencies are expected to maintain documentation of approvals, risk assessments and supervisory verifications to support audits and future improvements. While the annex does not prescribe a single central registry of AI tools, it places responsibility on each organism to keep adequate records and to coordinate with central digital governance units for oversight and shared learning.

Penalties, Liability, and Appeals

The annex itself focuses on obligations and prohibitions but does not enumerate a distinct fines schedule. Enforcement is expected to proceed through existent administrative, disciplinary and legal channels established under provincial law; improper uses (e.g., breaches of confidentiality, unauthorized access or security-compromising behavior) may trigger disciplinary sanctions, revocation of access credentials, administrative liabilities, and referral to prosecution where statutory crimes or regulatory breaches occur. The resolution references the requirement to report incidents to the Dirección Provincial de Sistemas Informáticos y Tecnología and to follow applicable rules on data protection. Agents subject to administrative measures retain the right to internal appeal mechanisms and judicial review in accordance with the provincial administrative law framework.

Relationship to Other Instruments

Resolución 4/2025 situates the annex within a preexisting legal and organizational framework: it cites provincial laws and decrees that define ministry structures and competencies (as reflected in the resolution preamble and the Dirección Provincial’s mandates). The document operates as procedural and technical guidance to be read alongside higher-rank statutory instruments on data protection, public administration conduct, cybersecurity and general administrative procedure. It complements other subnational and sectoral instruments (for example judicial or prosecutorial internal rules adopted in other provinces) by providing minimum standards tailored to the Province of Buenos Aires. Agencies are advised to align internal rules with the annex while observing national-level obligations and sector-specific legislation when applicable.

International Alignment

Although a provincial instrument, the annex references international best-practice orientations and invites participation in national and international fora. The guideline’s emphasis on human oversight, impact assessment, transparency, and data minimization reflects principles found in many transnational AI policy frameworks (eg. OECD principles, EU AI Act inspiration, and various UN/UNESCO recommendations). The Dirección Provincial de Innovación Digital is expressly tasked with engaging in cross-jurisdictional exchanges and aligning provincial practice with evolving international standards, contributing to harmonized approaches while preserving local administrative autonomy and compliance with Argentine law.

Implementation Timeline

Sources and References