The EU has published its ‘AI Continent Action Plan’ (COM(2025)165).
The Plan aims to enhance the EU’s AI capabilities by promoting initiatives around five key areas. One of those key areas concerns the promotion of AI in strategic sectors and, in particular, in the public sector and healthcare.
The Plan includes some high level initiatives that are, however, not new.
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The Plan refreshes the expectation for the public sector to provide a source of funding and experimentation for AI development: ‘EU public procurement, accounting for over 15% of our GDP, could create an enormous market for innovative products and services.’ This has been a long-standing aspiration (eg Fostering a European approach to Artificial Intelligence, COM(2021)205).
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In that regard, the Plan reiterates the goal of the Competitiveness Compass to promote ‘European preference in public procurement for critical sectors and technologies in the context of the forthcoming review of the EU rules’, and clearly places AI amongst them. We will have to wait for details, but the compatibility of an EU preference with international procurement law escapes me.
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The Plan also refers to the upcoming ‘Apply AI Strategy’ which should ‘address adoption by the public sector, where AI in areas like healthcare can bring transformative benefits to wellbeing’.
The Plan also includes a reference to:
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a call for funding of up to four pilot projects aimed at accelerating the deployment of European generative AI solutions in public administrations; and
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the fact that the ‘GovTech Incubator initiative will, over the period 2025-2029, support 21 GovTech actors from 16 countries to co-pilot and develop, as a first step, AI solutions for public procurement, evidence processing and accessibility assistants.’
Overall, while it is interesting to see procurement being highlighted as part of the Plan, it seems that the Plan is not at the right scale to promote the sort of system-level change required for extensive adoption of AI in the public sector (at Member State level).
What is more, without a clear strategy on how to address the issues of digital skills within the public sector, and without specific practical tools or guidance on how to procure AI (and the model EU clauses are definitely not an adequate tool, see here), it is hard to see how there can be much movement outside pilot projects. Perhaps the ‘Apply AI Strategy’ will provide some developments on those fronts.