In August 2026, AI³ submitted a formal response to the Deputy Ministry of Research, Innovation and Digital Policy on the draft National AI Strategy of the Republic of Cyprus 2032, through the government's e-Consultation platform.
Every proposal follows the same structure. It names the sections of the Strategy it affects, states what the draft currently says, sets out the change we recommend, and explains the reasoning behind it. Fourteen of the twenty-six proposals require no new institution and no significant new expenditure.
We regard the draft Strategy as a serious and candid document. It names the risk of running many pilots with little real impact. It anchors national ambition in European law rather than in a parallel national rulebook. It treats data as foundational infrastructure. Our submission seeks to strengthen the Strategy, but not to redirect it.
- A citizen-centric approach: the Strategy speaks about citizens often but gives them few enforceable rights and no seat at the governance table.
- Responsible AI put into practice, not just stated as a principle: the ethical commitments are sound, but the method, the owner, the point in the process where they apply, and the consequence for not following them are missing.
- AI sovereignty defined in practical terms: the Strategy uses the word sovereignty in at least three different senses, and sovereignty that is not clearly defined cannot be planned, budgeted, procured or measured.
- Citizens appear as beneficiaries rather than as participants with rights of their own. There is no public register of state AI systems, no single statement of what a citizen can demand, no guaranteed alternative route to a public service, and no standing role for civil society, which is mentioned once in a document of over one hundred pages.
- Responsible AI is described but not put into practice. There is no single national methodology for assessing impact on fundamental rights, no published incident and redress mechanism, no standard procurement clauses, and no obligation to publish what goes wrong.
- Sovereignty is asserted across compute, data and skills, but the model layer is largely absent and the plans for testing and oversight are underdeveloped. The Strategy also never names the Greek language, despite eighteen references to multilingual services.
- Several provisions applying to the private sector would create legal uncertainty, in particular conditioning the grant or renewal of operating licences on disclosure of a company's AI strategy, using terms that are nowhere defined.
- The delivery plan is not proportionate to the scale of the country, the financial commitment is not stated, and the headline targets do not match each other or the Strategy's own baseline data.
- A Citizen AI Charter, published in Greek and English, stating what a person can demand when a public body uses AI in a matter affecting them, with a response time and a named contact for each right.
- A public register of AI systems used by ministries, public law bodies and local authorities, scoped by risk, following an existing international format rather than creating a new national one.
- Clarification of which body does what, since the Strategy contains two separate diagrams of who is responsible for what, and they do not reference each other. Neither of the Commissioners designated under the AI Act appears in either one.
- A dated commitment on the national AI regulatory sandbox required by Article 57 of the AI Act, which Cyprus must have operational by 2 August 2027 and which the Strategy currently does not mention.
- Correction of the private-sector licensing provisions, the most urgent single change in our submission because they carry legal consequences for third parties as drafted.
- A clear, five-part definition of AI sovereignty covering infrastructure, data, models, applications and oversight, and talent, with an intended position on each by 2032.
Language. Greek-language corpora, terminology resources and evaluation benchmarks, including Cypriot Greek, so that procurement can tell a system that genuinely performs in Greek from one that is machine translated. Cyprus should own the data and evaluation layer and participate in European model development rather than finance a national foundation model.
Procurement. Replace the Strategy's AI-first procurement framing with a problem-first framing, which the Strategy's own design principles already require. Standard contractual requirements should cover audit, portability, exit and lifecycle cost, and flagship programmes should be divided into lots that small Cypriot suppliers can bid for, since standard turnover and prior-contract thresholds exclude every domestic company by definition when the country has never run a programme of that scale.
Sustainability. Cyprus operates an isolated electricity grid and faces severe water stress, and data centre cooling is water intensive. We recommend energy and water reporting under the Energy Efficiency Directive, published annually and weighted in procurement.
Delivery. A costed plan with named owners, dated milestones set from the date the Strategy is adopted, one mandatory independent mid-point review in 2029, and an annual report to the House of Representatives.
Institutional scale. The draft proposes eleven or more new bodies for a country of roughly one million people. Our concern is practical, not theoretical: the same small pool of senior people would be needed both to staff the committees and to deliver the systems.
Our distinctive contribution is comparative and legal rigour. The proposals draw on laws, guidelines and frameworks already in use in the Netherlands, the United Kingdom, Spain, Germany, Estonia, Portugal, Canada, the United States, the European Commission and the Council of Europe, chosen because they already work in states of comparable scale.
Drafts were shared with external reviewers, including from industry, ahead of submission. All editorial decisions in the final document are AI³'s own.
AI³ has offered to contribute to implementation at no cost to the Republic, through comparative research, bringing different stakeholders together for dialogue, support for international positioning, and independent review of draft implementation documents.