German supervision of AI Act transparency (KI-MIG; Bundesnetzagentur and the Landesmedienanstalten)

What it requires

The KI-Marktüberwachungs- und Innovationsförderungsgesetz (KI-MIG) assigns the AI Act's national roles. The federal digital ministry announced on 29 July 2026 that the law was in force and that the Bundesnetzagentur is the national coordinating body, market surveillance authority, single point of contact and complaints body, and runs an AI service desk and AI regulatory sandboxes; BaFin received separate competences for AI tied to regulated financial activity. Germany applies the AI Act on a hybrid model: the Bundesnetzagentur's own release of the same date states that in fully harmonised product areas the established market surveillance and sectoral authorities remain competent, naming the financial regulator in the financial sector and the state media authorities in the media sector (die Landesmedienanstalten im Medienbereich), while the Bundesnetzagentur acts in product areas not previously regulated at federal level and supervises the transparency obligations only within its own areas of competence, which it lists as radio equipment, human-resources management, critical infrastructure and education. The same release allows the Länder to call on the Bundesnetzagentur by way of Organleihe, so the competent authority and the acting authority need not be the same body.

Why it bears on this field

Article 50 is enforced nationally. The areas the Bundesnetzagentur lists as its own do not include microdrama apps, and its release names the state media authorities for the media sector. The release does not classify a vertical-drama app as a fully harmonised product area, and it does not say which of the fourteen state media authorities supervises such apps. No state media authority has itself published on Article 50 labelling. Medien.Bayern GmbH, a subsidiary of the Bavarian authority, published an explainer and FAQ on 30 July 2026, which is a guidance piece and not a claim of competence.

Open questions

• Which of Germany's fourteen state media authorities is competent for on-demand apps, and on what test? The release does not say.
• Is a vertical-drama app a fully harmonised product area within the meaning of the Bundesnetzagentur's release?
• How does section 111(5) of the Medienstaatsvertrag — which commentary reports as designating the state media authorities as market surveillance authority for Article 50 transparency in broadcasting and telemedia — fit with the KI-MIG's hybrid model?
• How often will the Länder use the Organleihe route, which separates the competent authority from the acting one?

Timeline

• 2026-07-28Promulgation in the Bundesgesetzblatt. Several third-party accounts give this date as the entry into force, which it is not.
• 2026-07-29The federal digital ministry announces in press release 47/2026 that the KI-MIG is in force and that the Bundesnetzagentur is national coordinator and market surveillance authority for the AI Act. Some third-party accounts date entry into force to 2 August 2026 instead. Several also render the statute's name as KI-Management- und Implementierungsgesetz; the ministry's own text uses KI-Marktüberwachungs- und Innovationsförderungsgesetz. Source (opens in a new tab)
• 2026-07-29The Bundesnetzagentur sets out the hybrid supervision model, splitting oversight by subject-matter proximity and naming the state media authorities as the retained authorities in the media sector. Source (opens in a new tab)
• 2026-07-30Medien.Bayern GmbH, a subsidiary of the Bavarian state media authority, publishes an Article 50 explainer and FAQ. Source (opens in a new tab)
• 2026-08-02The AI Act's market surveillance provisions for Annex III systems begin to apply in Germany; those for Annex I follow on 2 August 2027. Source (opens in a new tab)