Disruptive Actors and Normative Expansion: Post-AI Act Governance in the European Union

This article reconceptualizes the European Union’s Artificial Intelligence Act (AIA) as a catalyst for recursive governance rather than a static legal instrument. While existing scholarship has examined regulatory overlaps with the General Data Protection Regulation (GDPR), particularly in relation to high-risk AI systems and compliance burdens, it has largely overlooked how the AIA transforms the broader governance ecosystem. The research asks: How do peripheral and non-formally embedded actors influence the trajectory of AI governance in the EU following the AIA’s adoption? The central hypothesis is that disruptive actors—including the European Data Protection Board (EDPB), national regulators, and regional infrastructure initiatives—reshape post-AI Act governance by injecting citizen-centric accountability and expanding regulatory norms beyond the Act’s formal legal architecture. Empirical analysis of institutional consolidation (AI Office, AI Board), Member State innovation (Spain’s ALIA, Barcelona AI Factory), and strategic interventions by non-embedded bodies (EDPB) demonstrates how legal codification activates multi-scalar feedback loops and pluralistic norm expansion. The article contributes to experimentalist governance literature by showing that post-legislative regulation is shaped by infrastructural experimentation, normative turbulence, and strategic behavior at the margins. The EU’s AI regime emerges as a living system—where law, infrastructure, and contestation co-evolve in real time.

کلیدواژه ها:

Recursive governance ، AI Act ، Normative Contestation ، Peripheral Actors ، Post-Legislative Regulation