A documented case of "the application that circulated": an enquiry concerning EU
Regulation 2024/1689 (the AI Act) passed between authorities, traced on the basis of letter
file references and Official Delivery Acknowledgements (UPO) of the e-Delivery system. Aim: to show how the
technology layer (the evidence layer) makes an administrative process auditable.
STATUS: DATA7 e-Delivery UPOAI Act: EU Reg. 2024/1689
Not against AI — against AI without accountability.
And accountability begins with a trace: who, when, to whom and with which file reference.
This case attributes no blame to any authority. It documents solely the
procedural events confirmed by delivery evidence. "No response within the time limit" is a
procedural fact, not an accusation.
Labelling convention. Each entry is classified as:
FACT confirmed by evidence (letter / UPO) ·
OBSERVATION interpretation based on facts ·
GAP no evidence = a gap, not a conclusion.
Overriding principle: claim ≤ proof.
1. Context — the AI Act and the division of obligations
Regulation (EU) 2024/1689 of the European Parliament and of the Council (the AI Act) establishes
harmonised rules for artificial intelligence in the EU. Among other things, it requires Member States
to designate competent authorities, establish market surveillance and — in the area of public administration —
implement procedures for high-risk AI systems.
Obligations of authorities
Designation of a competent authority, market surveillance, register of high-risk AI systems,
handling of applications and referral of matters according to competence (Code of Administrative Procedure, KPA).
Obligations of companies / deployers
Risk classification, technical documentation, human oversight, event logging
(logs), risk management and transparency towards the user.
OBSERVATION The flashpoint is the interface: when an entity directs
an enquiry about AI Act readiness to the administration, it becomes crucial to determine the
competent authority and to observe the time limits of the Code of Administrative Procedure (KPA). It is precisely this interface that
this case documents.
Scope disclaimer: this page does not interpret the substantive content of the AI Act
nor does it formulate legal conclusions about the compliance of any authority — see the triad of disclaimers below.
2. Events — timeline (documented only)
The timeline below covers only events backed by a letter file reference or an Official Delivery
Acknowledgement. Dates and file references that could not be confirmed by evidence are marked as
GAP and are not presented as facts.
[stage 1]FACT
Submission of an enquiry / application concerning the AI Act by K0NSULT to the authority
that was the first addressee; dispatch via the e-Delivery system.
Evidence: e-Delivery UPO (item 1 of 7).
[stage 2]FACT
Referral of the matter according to competence — route: UODO → RCL →
Ministry of Digital Affairs. Each referral confirmed by a separate UPO.
Evidence: e-Delivery UPO (subsequent items).
[stage 3]FACT
Response from CERT.PL.
File reference: #5801646.
[stage 4]FACT
Response from the Ministry of Digital Affairs (MC).
Case file reference: DPNT.056.5.2026.
[closure]FACT
In total, 7 e-Delivery UPO were registered, along with substantive
responses from the authorities indicated.
Evidence: full set of UPO + letter scans in the evidence index.
7e-Delivery UPO (FACT)
3authorities in the referral route
2response refs (CERT.PL, MC)
1MC case ref (DPNT)
GAP The exact calendar dates of the individual UPO
and the full text of the letters are not cited on this page until they are published in the
evidence index. Until publication, the marking remains: n/a (GAP),
not conjecture.
3. Legal conclusions — who is responsible, where the gaps are
What is fact
FACT The application concerning the AI Act was effectively dispatched
and was passed between authorities according to competence — each move has a UPO confirmation.
FACT Responses were obtained from at least two sources
(CERT.PL #5801646, MC / DPNT.056.5.2026).
FACT The e-Delivery system produced 7 independent,
verifiable acknowledgements — a ready-made evidence layer for the process.
What is observation
OBSERVATION The repeated referral "according to competence"
indicates that determining the competent authority for AI Act matters can be non-obvious at the point
a letter enters the administration system.
OBSERVATION Where the referral route is long, the
risk of exceeding the KPA time limits rises — which makes the auditable trace (UPO) all the more important.
Where the procedural gaps are
GAP There is no single, explicit "entry point" for AI Act
enquiries to the administration — until one is designated, mapping of competence rests on the KPA
and the sender's knowledge.
GAP There is no public register of AI Act matters with numbers and
statuses — without it, a citizen/company cannot track a matter in real time.
GAP Any "no response within the time limit" is recorded here
as a procedural fact derived from the UPO dates, without attributing blame
to a specific official or authority.
4. The technology layer — what it solves
The very same process that today requires manually stitching UPO together can be made natively auditable.
This is the practical meaning of the "evidence layer" in the ENVOIS ecosystem.
Evidence layer
Each event (dispatch, referral, response) as an entry with a hash, timestamp and
evidence (UPO). An immutable chain instead of loose PDFs.
Auditability
Reconstruction of the full case history from a single source: who, when, to whom, with which file reference
and what the outcome was — without reconstructing it from emails.
Register of AI systems
Linking the matter to the register of AI systems (an AI Act requirement for high risk): from enquiry
to register entry in a single, verifiable view.
Engineering conclusion.
The matter "circulated", but it was not lost — because every move left a UPO.
Had the same trace been generated automatically and publicly status-tracked, the "circulation" would have been
visible live, and the KPA time limits would have been monitored by machine. That is the difference between evidence
reconstructed after the fact and evidence recorded in real time.
Disclaimer. This material is informational, research and documentary in nature.
It does not constitute a certification, it is not an opinion of a notified body, nor a legal conclusion
(not a certification · not a notified body · not a legal conclusion).
The events described reflect solely the state documented by delivery evidence; they do not
attribute blame to any authority or person. Details of the disclaimers:
/legal/not-certification.