Subject: Estonia's regulatory framework for ADM and AI within public authorities
From: Meritähti Maisa (OM) <[email-masked]>
To: <[email-masked]>, "Justiits- ja Digiministeerium" <[email-masked]>
Date: Fri, 20 Mar 2026 09:25:43 +0200

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear recipient,

I am contacting you from the Finnish Ministry of Justice. I would be very 
grateful if you could point me toward the right person in your Ministry.

We are currently conducting a preliminary study project on the use of AI in 
administrative procedure (information on the study available in Finnish 
<https://valtioneuvosto.fi/hanke?tunnus=OM063:00/2025> here).  The aim is to 
determine the legal conditions for using AI at different stages of the 
procedure – from the initiation of a matter to the final decision.

As part of this study, we are carrying out a brief comparative legal 
analysis on the regulation of AI in administrative procedures in various 
European countries, including Estonia.

We have taken note of your 
<https://eelnoud.valitsus.ee/main/mount/docList/d5f01f2e-07bb-47f7-9536-564c7c136b2b#KHIqFcM7> 
legislative proposal on enabling automated decision-making (ADM) within 
public authorities and would like to ask a few questions.

*	According to the proposal, the new legislation would be technology 
neutral. Algorithms may make discretionary decisions if the discretionary 
factors are predetermined by standardized rules. The number of options must 
be limited, and the system then selects the appropriate solution according 
to its internal logic.

*	Does this mean that the proposal would not permit the use of more 
autonomous AI (i.e., more advanced than rule‑based AI and within the scope 
of the AI act) in administrative procedures?
*	How would you define "technology-neutrality" in the context of the 
proposal?

*	Would the scope of the proposed regulation apply only to the use of 
automated decision‑making for the final formal administrative decision?

*	If so, would the use of more advanced AI be permitted in other stages of 
the administrative procedure, such as the initiation of a matter?

*	Additionally, we would be interested to hear whether, in the context of 
the project, you have considered the legal conditions for the use of more 
autonomous AI, and whether any related preliminary work is currently 
underway.

Thank you very much in advance for your time and assistance. Please do not 
hesitate to contact me should you require any further information.

Best regards,

Maisa Meritähti

Specialist
Department for Democracy and Public Law
Ministry of Justice of Finland

Email:   <mailto:[email-masked]> [email-masked]
Tel. +358 295150159

 <http://www.oikeusministerio.fi/> www.oikeusministerio.fi

PL 23  |  00023 Valtioneuvosto

 <https://valtioneuvosto.fi/> valtioneuvosto.fi