DADM Compliance Deadline for Legacy Systems: What Your Department Must Do Before June 2026
Published March 2026
~8 min read
Key Deadline
If your system was developed or procured before June 24, 2025 and is still in production, you must bring it into full compliance with the current Directive by June 24, 2026.
Section 1.2.1 of the Directive on Automated Decision-Making. Agents of Parliament: same date, section 1.2.2.
Who This Is For
Digital governance leads, CIOs, program owners, and consultants responsible for existing automated decision systems.
Critical Alert: Peer Review Bottleneck
If you need peer review, you are already late if you have not identified reviewers. Peer review is the longest lead-time activity. Reviews take one to three months. Qualified reviewers with the right domain expertise and security clearances are scarce. If 50 departments all commission reviews in Q1 2026, the pipeline will be overwhelmed. Start here.
What "Current Directive" Means for Legacy Systems
The key phrase is "new or updated requirements." The third review (April 2023) expanded scope to internal services, mandated peer review publication, introduced GBA+ requirements, added explanation criteria, and strengthened bias testing. If your system's AIA predates April 2023, it almost certainly needs to be re-done.
Which Systems Are Affected
Every automated decision system procured or developed before June 2025 that is still in production. Internal-facing systems (hiring, performance scoring, resource allocation) are now in scope since the third review.
Compliance Timeline
Now
Inventory all in-scope systems. Identify peer reviewers. Assign workstream owners.
Month 1–2
Complete/re-complete AIAs under current questionnaire. Commission peer reviews.
Month 2–4
Peer review in progress. Build notice + explanation frameworks in parallel. Conduct GBA+.
Month 4–5
Peer review complete. Finalize all documentation. Prepare bilingual publication materials.
Before June 24, 2026
Publish AIA results + peer review on Open Government Portal. Both official languages. Accessible format.
The Six Workstreams
Inventory in-scope systems
Map every ADS. Most teams find systems they forgot about.
Complete/update the AIA
Current questionnaire (65 risk + 41 mitigation). Old versions do not count.
Commission peer review (Level II+)
CRITICAL PATH. 1–3 months. Start here first.
Notice + explanation frameworks
Parallel with peer review. Per-decision explanations at Level II+.
GBA+ analysis (Level II+)
Retroactive if system predates requirement.
Publish on Open Government Portal
AIA + peer review. Bilingual. Accessible. Before deadline.
What Happens If You Miss It
The Directive does not prescribe fines. But the fourth review proposes ADM-level sign-off and public annual compliance summaries. Non-compliance becomes visible. In a government context, that is its own enforcement mechanism. See our compliance page for a full breakdown of what each deadline requires across the Directive.
Key Takeaway
Meeting this deadline is not a research problem. You know what needs to happen. The hard part is tracking six workstreams across multiple systems with multiple owners against a fixed date. That is not a knowledge problem. It is a project management problem. If your team needs tooling to manage this, see our plans.