Regulating future AI systems - enabling future AI innovation through an increased level of legal certainty in technology neutral regulation

Academy of Finland project 09/2022-08/2026, grant number: 347221

In the AI-REG project we study ambiguity that arises from the European Artificial Intelligence Act proposal (AI Act) that has been proposed by the European Commission in April 2021. The AI Act would regulate the development and use of AI systems in Europe.

The underlying goal of the AI Act is to ensure that Europeans could trust  AI systems. The AI Act distinguishes 4 risk classes of AI systems: unacceptable-, high-, limited-, and minimal risk. AI systems which would be judged to have unacceptable risk would be outright forbidden, and high-risk AI systems would have to conform to requirements both during development of the system and in the use of such a system. The AI Act is thus expected to heavily affect the development and use especially of high-risk AI systems. However, the AI Act is also ambiguous on many parts, beginnig with the definition of what will be classified as an AI system, or how a specific system would be classified as high-risk vs. low-risk system. Ambiguity means that something can be interpreted in several different ways, and ambiguity in legal regulation is potentially problematic as it reduces legal certainty.

The AI Act is a horizontal and broad regulation proposal. In the AI-REG project we have two focus areas: 1) High risk AI-system use in public sector organizations, and 2) Development of high-risk AI-based healthcare technology.

In the AI-REG project, we study

  • What kind of ambiguities arise from the AI Act
  • What legal formulations and requirements cause the ambiguity
  • What characteristics of AI systems make an AI system subject to ambiguity
  • How does regulation affect development of AI-based healthcare technology and AI-system use in public sector organizations
  • How to organizatios prepare for the upcoming AI Act, and how do they deal with ambiguity arising from the Act?

In the AI-REG project, we have a qualitative research approach

  • Analysis of the AI Act proposal, its subsequent versions, and statements on the proposal to identify ambiguity and which legal formulations they arise from.
  • Interviews in Finland, Sweden and Norway, with 1) public sector organizations that use AI systems, and 2) organizations that develop AI-based healthcare technology.
  • Collect examples of AI systems to figure out how to characterize AI systems in light of the law and whether it is possible to develop a taxonomy.

The People

Karin Väyrynen, Ph.D. (Principle Investigator) Arto Lanamäki, Ph.D Fanny Vainionpää, Ph.D.


Heidi Hietala, MSc

doctoral researcher          

Erkki Tervo, MSc

doctoral researcher    


21.10.2023: We were happy to welcome Prof. Mika Viljanen, Professor of private law at the University of Turku, who gave a 2-day Infotech-seminar called "AI regulation for non-lawyers". Thank you, Mika, for sharing your expertise with us and a very interdisciplinary group of participants! :)

10.10.2023: Karin participated in a 2-day visit to the European Parliament, arranged by MEP Miapetra Kumpula-Natri. 2 days full of expert talks by those who have been and are involved in negotiating the AI Act, new insights into the process and the latest status updates, and so so many interesting discussions with all the other expert participants. I am very grateful to have been invited to this! <3  Some pictures can be found here

03.10.2023: Good news from ICIS - our literature review on challenges and critique about the AI Act, with propositions for new research avenues for IS, has been accepted at the International Conference on Information Systems, which will be held in December in India. 

14.10.2023: The reserach visit to Sydney has been fantastic!! Some impressions can be found here

01.10. 2023: Karin and Arto landed in Sydney to start their 2 week research visit with Prof. Lyria Bennet Moses (University of New South Wales, Department of Law and Justice). They are looking forward to exciting discussions with legal scholars, and will also visit the University of Sydney School of Business (Prof. Dirk Hovorka) and look forward to discussions with IS scholars as well.     

05.-12.05.2023: Arto has visited Legal Tech Lab (hosted by Prof. Riikka Koulu and Prof. Suvi Sankari), and has had numerous discussions with legal scholars which was an eye-opening experience and has a big influence on the direction the project will go.                                                                


  • Vainionpää, F., Väyrynen, K., Lanamäki, A., and Bhandari, A. (2023). A Review of Challenges and Criticisms of the European Artificial Intelligence Act. Accepted for publication in Proceedings of the International Conference on Information Systems (ICIS)
  • Väyrynen, K.,  Lanamäki, A., Laari-Salmela, S., iivari, N., Kinnula, M. (2022) Policy Ambiguity: a Problem, a Tool, or an Inherent Part of Policymaking? Proceedings of the International Conference on Informaiton Systems (ICIS), Copenhagen, Denmark  AIS Electronic Library (AISeL) - ICIS 2022 Proceedings: Policy Ambiguity: a Problem, a Tool, or an Inherent Part of Policymaking? (
  • Konttila, J., Väyrynen, K. (2022). Challenges of current regulation of AI-based healthcare technology (AIHT) and potential consequences of the European AI Act proposal. Proceedings of the 13th Scandinavian Conference on Information Systems (SCIS), Denmark.

Master's Theses

Upcoming and Past Seminars

  • "How to publish in top-IS journals" by Prof. Mikko Siponen (University of Alabama): June 2024 (exact data to be confirmed), University of Oulu, Infotech seminar
  • "AI Regulation for Non-Lawyers" by Prof. Mika Viljanen (University of Turku, Finland): 20.-21.11.2023, University of Oulu, Infotech seminar
  • "AI-Enabled Futures" by Prof. Dirk Hovorka (University of Sydney, Australia): 19.+20.6.2023, University of Oulu. Infotech seminar