Lithuania - AI Act Implementation Amendments (XV-105, XV-106)

Overview

In January 2025 the Seimas of the Republic of Lithuania adopted a linked package of amendments to two national laws — the Law on Technology and Innovation (amendment adopted as Act No. XV-105) and the Law on Information Society Services (amendment adopted as Act No. XV-106) — to implement key domestic obligations arising from the EU Artificial Intelligence Act (Regulation (EU) 2024/1689). The amendments were published in the official register (TAR) on 22 January 2025 and most of the new provisions became effective on 1 April 2025, with several provisions staged to enter into force on other specified dates. Full text of the principal amendment is available in the official register: https://www.e-tar.lt/portal/it/legalAct/9c30a402d88811efa5ddd96c482819f5.

Definitions

This package uses the following key terms (as applied in the national amendments and for implementation of Regulation (EU) 2024/1689): Innovation Agency (Inovacijų agentūra) — the national notifying authority responsible for assessing and helping to notify conformity assessment bodies; Communications Regulatory Authority (Ryšių reguliavimo tarnyba, RRT) — the national market surveillance authority and single point of contact; notified/conformity assessment bodies — independent entities (companies, research institutions, certification bodies, etc.) that may be notified to perform conformity assessment for high‑risk AI systems; AI regulatory sandbox (DI smėliadėžė) — a controlled pilot environment for testing AI systems with regulatory supervision; providers and deployers — actors placing AI systems on the market or using them (including high‑risk systems listed in Annex III of the EU AI Act); market surveillance — inspections, investigations and enforcement activities undertaken by the designated national authority. If additional formal legal definitions are required, readers should consult the official Acts in the State Gazette (TAR) listed in Sources.

Governance and Institutional Framework

The amendments allocate national roles and responsibilities to implement the EU AI Act. Principal national actors and their primary functions under the amendments are:

• Innovation Agency (Inovacijų agentūra): designated as the national notifying authority; tasked with assessing competence of domestic conformity assessment bodies, supporting notification procedures, and establishing/operating an AI regulatory sandbox.
• Communications Regulatory Authority (Ryšių reguliavimo tarnyba, RRT): designated as the national market surveillance authority and the single point of contact to liaise with the European AI Office and other Member State authorities; responsible for market surveillance, inspections and cross‑border cooperation.
• Other oversight bodies: the State Data Protection Inspectorate, the Consumer Rights Protection Service and other sectoral authorities retain or have specified roles for data protection, consumer protection and sectoral oversight where relevant.

The national arrangements are intended to provide the institutional infrastructure required by Regulation (EU) 2024/1689 and to enable cooperation with EU bodies and other Member State authorities.

Key Focus Areas

• Designation of national competent authorities: the amendments explicitly designate the Innovation Agency as the notifying authority (for assessing and assisting the notification of conformity assessment bodies) and RRT as the market surveillance authority and single contact point. e-tar.lt
• Notified/conformity assessment bodies: procedures and administrative responsibilities are created for the Innovation Agency to assess the competence of potential conformity assessment bodies that may be notified under the EU AI Act. eimin.lrv.lt
• AI regulatory sandbox (DI smėliadėžė): the package mandates the creation and operation of a controlled AI regulatory pilot environment within the Innovation Agency to support testing, compliance support and capacity‑building for businesses (with statutory timetables targeting sandbox establishment and operational tasks by early 2026). eimin.lrv.lt
• Information Society Services alignment: amendments to the Information Society Services Act update definitions and the functions of RRT, the State Data Protection Inspectorate and consumer protection services to ensure they can perform DSA/AI Act duties, explicitly referencing Regulation (EU) 2024/1689 and Regulation (EU) 2022/2065 (DSA) in the amended text. e-tar.lt
• Startup support & institutional consolidation: the Technology & Innovation Act amendments create a legal basis for the consolidated Innovation Agency to assess start‑ups’ innovation potential (refining the definition of 'start‑up') and to prioritise support for AI‑relevant ventures as part of economic competitiveness measures. e-seimasx.lrs.lt

Implementation Framework

The national amendments function primarily as implementing measures for Regulation (EU) 2024/1689: they do not create a separate, standalone domestic AI Act but assign national authorities, procedural roles and infrastructure required under the EU Act. Core elements of the implementation framework include:

• Assessment and notification procedures: administrative procedures for the Innovation Agency to assess and assist domestic conformity assessment bodies so those bodies can be notified to perform conformity assessment for high‑risk AI systems under the EU AI Act.
• Sandbox operations: statutory requirements and timelines for establishing an AI regulatory sandbox within the Innovation Agency to offer testing, technical and compliance advisory services to participants (with EU and national funding allocated for pilot phases).
• Market surveillance and single contact point: RRT is given responsibilities and procedural tools to conduct market surveillance, inspections, incident handling and cross‑border cooperation in line with EU requirements.
• Coordination among oversight bodies: clarifications in the Information Society Services Act to enable cooperation between RRT, the State Data Protection Inspectorate, consumer protection services and other authorities for digital services and AI‑related oversight.

Operationalisation steps are underway, including procurement, calls for sandbox participants and allocations of funding for pilot activities.

Monitoring and Evaluation

Monitoring and evaluation are to be conducted through the national authorities with coordination mechanisms to support EU‑level oversight and cross‑border cooperation. Recent implementation developments include government allocations (approximately €3 million earmarked for sandbox activities across selected regions) and the Innovation Agency publishing calls and informational material for sandbox participants. RRT has signalled the need for budgeted resources to undertake its new market surveillance tasks. These implementation steps — staffing, funding, published procedures and sandbox pilot outcomes — will form the basis for evaluating readiness to support full application of the EU AI Act.

Penalties, Liability, and Appeals

Enforcement, penalties and administrative fines for substantive breaches of the AI Act (for example banned practices, high‑risk system requirements, conformity assessment, transparency and incident reporting) are primarily established at EU level in Regulation (EU) 2024/1689. The Lithuanian amendments generally do not recreate parallel penalty regimes; instead they provide the national institutional structure (market surveillance authority, notifying authority, single contact point) and procedural tools through which the EU enforcement architecture and national market surveillance may be exercised. The amendments also require national budgeting and resourcing to enable RRT and other oversight bodies to exercise enforcement powers entrusted by the EU framework. Specific domestic procedural enforcement measures and appeal routes will operate within the broader EU enforcement architecture and relevant national administrative law procedures.

Relationship to Other Instruments

The national amendments explicitly implement obligations arising from Regulation (EU) 2024/1689 (Artificial Intelligence Act) and align the Information Society Services Act with Regulation (EU) 2022/2065 (Digital Services Act) where duties intersect. The amendments therefore function as national implementing measures to enable conformity assessment, notification and market surveillance consistent with EU law. Authorities are required to coordinate with the European AI Office and follow cross‑sectoral rules where DSA/AI provisions interact.

International Alignment

These amendments are oriented to full compliance and cooperation with EU‑level AI governance instruments. Designations such as the single contact point and the market surveillance authority are intended to facilitate cross‑border cooperation with other Member States and with the European AI Office, enabling participation in the EU network for conformity assessment, market surveillance and information exchange as required under Regulation (EU) 2024/1689.

Implementation Timeline

Date	Event
2024-07-12	Publication of Regulation (EU) 2024/1689 (AI Act) in the Official Journal of the EU (OJ L 2024/1689). eur-lex.europa.eu
2024-08-01	AI Act entered into force at EU level (publication + entry into force; staged applicability follows). eur-lex.europa.eu
2025-01-14	Seimas adopted amendments to the Law on Technology and Innovation (Act No. XV-105) and to the Law on Information Society Services (Act No. XV-106). e-tar.lt
2025-01-22	Amendments published in the State Gazette (TAR). e-tar.lt
2025-04-01	Majority of the national amendments entered into force (with specific provisions phased in on other dates). e-tar.lt
2025-08-02	Certain procedural provisions in the Technology & Innovation Act amendments scheduled to come into force. e-tar.lt
2026-01-01	Target date for the Innovation Agency to have the AI regulatory sandbox established and operational under the statutory timetable. eimin.lrv.lt
2026-08-02	Broad applicability date for many provisions of the EU AI Act across the EU (staged timetable under Regulation (EU) 2024/1689). eur-lex.europa.eu

Compliance Checklist

Requirement	Description
Designation and Registration	Confirm whether your organisation must engage with national notifying authority (Innovation Agency) and whether any conformity assessment bodies to be used are or will be notified; prepare documentation for conformity assessment interactions.
Conformity Assessment Preparation	Plan for conformity assessment procedures for high‑risk AI systems (technical documentation, risk management, quality management) and identify potential notified bodies assessed by the Innovation Agency.
Market Surveillance Readiness	Prepare for possible market surveillance inspections and incident reporting related to high‑risk systems; ensure recordkeeping and incident response procedures align with national and EU requirements under RRT oversight.
Sandbox Engagement	If seeking to use the AI regulatory sandbox, monitor Innovation Agency calls and application processes (sandbox is targeted to be operational by 2026‑01‑01) and gather materials for pilot testing and compliance support.
Data Protection and Consumer‑Rights Coordination	Ensure coordination with data protection and consumer protection obligations (State Data Protection Inspectorate and Consumer Rights Protection Service may be involved in oversight); update privacy impact assessments and consumer information as required.
Resourcing and Funding	Plan internal resourcing to meet compliance (technical, legal, recordkeeping) and consider applying for available national/EU support for sandbox participation or capacity building.

Sources and References

Source	URL
Lietuvos Respublikos technologijų ir inovacijų įstatymo Nr. XIII-1414 — pakeitimo įstatymas (Act No. XV-105) — e‑TAR (official register)	https://www.e-tar.lt/portal/it/legalAct/9c30a402d88811efa5ddd96c482819f5
Lietuvos Respublikos informacinės visuomenės paslaugų įstatymo — pakeitimo įstatymas (Act No. XV-106) — e‑TAR (official register)	https://www.e-tar.lt/portal/tt/legalAct/e351b770d88811efa5ddd96c482819f5
Regulation (EU) 2024/1689 (Artificial Intelligence Act) — EUR‑Lex (Official Journal text)	https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=OJ%3AL_202401689
Ministry of the Economy and Innovation (EIMIN) — Seimas approves amendments to accelerate the development of artificial intelligence in Lithuania (official announcement)	https://eimin.lrv.lt/en/structure-and-contacts/news-1/seimas-approves-amendments-to-accelerate-the-development-of-artificial-intelligence-in-lithuania/
Ministry of the Economy and Innovation — AI regulatory sandbox (DI smėliadėžė) program page	https://eimin.lrv.lt/lt/veiklos-sritys/skaitmenine-politika/dirbtinis-intelektas/di-akto-igyvendinimas/di-smeliadeze/
Seimas (parliament) — legislative act and explanatory material regarding Innovation Agency provisions (official parliamentary register)	https://e-seimasx.lrs.lt/portal/legalAct/lt/TAD/51938be0d27711efbd239e318cbd5b26
Innovation Agency (Inovacijų agentūra) — official site and implementation news	https://inovacijuagentura.lt/site/news/2025
Seimas / Parliamentary portal — Communications Regulatory Authority (RRT) commentary and official submissions (official parliamentary materials)	https://e-seimas.lrs.lt/rs/legalact/TAK/809734b0a1cf11ef9db2c9aaf9c67042/