Challenge

How to achieve user trust in digital government services that use data and artificial intelligence algorithms, while ensuring their responsible, safe and fair use. 

Proposed solution: that each digital service includes, on its home page and on the Portal Transparència from the responsible entity, an understandable report on the operation of the system and the impact it can have on people.
→ See the PDF report template transparència AOC algorithm (updated 4/17/2026)

Problem and current context

Artificial intelligence (AI) has become an integral part of our daily lives. Governments use it to improve the accessibility and experience of public services, optimize processes or manage public space, for example.

Algorithms are the foundation of AI systems and often act like “black boxes” for the people who use and affect them. To prevent this from happening, it is essential that the algorithms can be understood by the users, that they can understand how a certain decision has been reached and why this decision is made. Even more so in the case of the government, which can only function when there is trust between it and the public. A good administration must allow all citizens to understand the reasons for decisions and to have the possibility of challenging them.

In democratic governments, trust is guaranteed by numerous legal safeguards. Regarding the obligation to make AI algorithms used in digital government services transparent, the law establishes the right of individuals to obtain an explanation of automated decisions (GDPR) and provides for the creation of “mechanisms” so that algorithms involved in decision-making take into account criteria of transparència and explainability (Comprehensive Law 15/2022 for equal treatment and non-discrimination), but does not establish any specific mechanism or legal instrument to do so. It only gives recommendations and leaves it to the discretion of the organizations to find the most suitable tool for:

  • provide meaningful information about the logic of the algorithms used as well as the expected consequences, which is clear and uses understandable language,
  • allow people to understand why an algorithm has given a certain result, as well as indicate the body before which they can appeal their particular decisions or contest its general operation,
  • open the algorithms to democratic control.

In view of the lack of concrete mechanisms, techniques or methods to achieve the transparència algorithmic, the AOC conducted a study in 2023 in order to find standardized forms of transparència and prioritize understanding the algorithms we apply to our digital administration services.

This is where the initiative of transparència algorithm that we present.

Proposed solution 

La transparència in the development and use of AI is a crucial issue to ensure that this technology is used responsibly and fairly towards society.

As a means to achieve the transparència algorithmic, the AOC proposes that each digital service include, on its homepage and on the Portal Transparència from the responsible entity, an understandable report on the operation of the system and the algorithms it uses.

This initiative aims to be a tool for:

  • help people understand how algorithms used in local governments work, what their purpose is and how they can affect them,
  • to provide a transparència meaningful in a standardized way and allow comparison between different algorithms,
  • make it easy for everyone to give their opinion and participate in the creation of human-centered algorithms.

Furthermore, although the initiative focuses mainly on artificial intelligence systems, also includes reports of transparència for deterministic algorithms in sensitive use cases, such as complex automation systems for wide-ranging social assistance, following the criterion that they can also have a relevant impact on people.

→ See the PDF report template transparència AOC algorithm (updated 4/17/2026)

Report content

Each report of transparència algorithmic contains:

  • the problem to be solved with the algorithm in question,
  • the explanation of the characteristics of the algorithm as well as its operation,
  • the groups that may be affected by the algorithm,
  • the estimation of the risk level of the algorithmic system, based on:
    • the risk analysis or fundamental rights impact assessment that has been carried out (as appropriate) to determine the possible discriminatory biases of the algorithm,
    • the security risk analysis of the system that has been done to identify the possible contingencies of availability and security of the system that contains the algorithm,
    • la risk management made and the measures applied to guarantee compliance with fundamental rights, 
  • the body before which it is possible to appeal against the particular decisions of the algorithm or challenge its general operation when the law requires it,
  • the contact details of the person in charge and of the supplier of the algorithm.

How the content of the report was determined

To determine the content of the reports transparència algorithmic, the Innovation and Data team with the support of the AOC's legal services, carried out, in 2023, a study that included:  

  1. An analysis of the existing regulations at that time in which the subject of the transparència of automated decisions made by AI algorithms, paying particular attention to the following rules:  
  • European Data Protection Regulation (RGPD)
  • Proposal for a Regulation on the use of artificial intelligence of the Council of Europe (AI Act)
  • Law 40/2015 on the Legal Regime of the Public Sector (LRJSP) and Regulations for the performance and operation of the Public Sector by electronic means (RD 203/2021)
  • Comprehensive Law 15/2022 for equal treatment and non-discrimination 
  1. Documents that offered guidelines and guidance to achieve a safe and reliable AI. It should be noted: 
  • Ethical Guidelines for Trusted AI, from the European Commission's High Level Expert Group on AI (April 2019) 
  • Report "Unboxing Artificial Intelligence: 10 Steps to Protect Human Rights" by the Commissioner for Human Rights of the Council of Europe (May 2019)
  • Principles for the Responsible Management of Trusted AI from the OECD Artificial Intelligence Council Recommendation (May 2019)
  • APDCAT “Automated Decisions in Catalonia” report (January 2020)  
  • European Declaration on Digital Rights and Principles for the Digital Decade (January 2023)
  • NIST Artificial Intelligence Risk Management Framework Tool (January 2023)
  1. They were also explored initiatives of transparència algorithmic of different administrations, which were in the development phase or recently implemented. It is worth noting: 
  • Register of Artificial Intelligence of the cities of Helsinki and Amsterdam – implemented
  • Standard of transparència Eurocities algorithm, based on the UK standard – implemented
  • Proposal for an ethics work framework for the algorithms of the Generalitat de Catalunya (May 2021)
  • Barcelona City Council's municipal algorithm registration model based on the standard of transparència from Eurocities (January 2023)
  • Collection of AI algorithms from the Catalan Health System (SISCAT) and research centers in Catalonia within the framework of the AI ​​Observatory in Health of the TIC Salut Social Foundation (December 2022)
  • Radar of AI algorithms of the Table of entities of the Third Social Sector of Catalonia (January 2024)

Conclusions of the study

The Member States of the European Union commit themselves, through the European Declaration on Digital Rights and Principles for the Digital Decade, to ensuring an adequate level of transparència in the use of algorithms and artificial intelligence and so that people are informed and trained to use them when interacting with them.

To comply with the requirement of transparència of the AI ​​systems of public administrations, current regulations specify the information that must be provided according to the cases [1], but does not define a "concrete" mechanism, standardized format or legal instrument for doing so; although: 

  • the AI ​​Regulation establishes the requirement to keep a record of all relevant information of high-risk AI systems (art. 17);
  • Law 15/2022 on equal treatment and non-discrimination speaks of promoting the implementation of "mechanisms" so that the algorithms involved in decision-making take into account criteria for minimizing bias, transparència and accountability (art 23);
  • the Regulation on the performance and operation of the Public Sector by electronic means establishes the obligation to publish on its website the list of automated administrative actions (AAA) - which may or may not involve the use of AI algorithms - , and accompany each AAA with a description of its design and operation (art. 11). 

We have explored different initiatives that are being promoted by European local and regional governments, in order to find a standardized way that allows us to comply with the requirement of transparència of the AI ​​algorithms we apply to our digital administration services.

Among all the initiatives explored and in accordance with the legal obligations in force, we have come to the conclusion that the publication of reports transparència algorithmic on the Portal of Transparència it's a quick and simple solution that facilitates compliance with the requirement of transparència established in the regulations i allows to gain the trust of the users in the AI ​​systems of public administrations.

The study also allowed us to determine what relevant information needs to be provided about AI-based public services so that users can understand how algorithms make decisions and how those decisions are verified. Otherwise, the study has led us to develop an agile and practical methodology to identify and analyze the most likely risks involved in the use of AI algorithms in relation to fundamental rights, and connect them with the measures that will need to be applied in each case to guarantee compliance with these rights.

Risk management methodology focused on the protection of fundamental rights

To guarantee reliable, ethical and safe AI in public services, the AOC has developed its own risk management methodology. This methodology, focused on the protection of fundamental rights, addresses the possible risks that may affect citizens and details how they can be mitigated or minimized. The methodology consists of three main steps, each with a solid foundation in international regulations and guidelines.

  • Step 1: Identification of fundamental principles and rights to be protected
    To ensure an AI that respects democratic values, we have relied on the Charter of Fundamental Rights of the European Union, which helps us define the main families of rights and principles that may be affected by AI. These are:

    • A) Equality and non-discrimination
    • B) Data protection, privacy and personal autonomy
    • C) Security, robustness and cybersecurity
    • D) Transparència, explainability and access to information
    • E) Responsibility, accountability and auditability
    • F) Social impact, sustainability and economic rights

  • Step 2: Identification of associated risks and their relationship with the principles and rights to be protected
    To identify the most common risks in the use of AI, the AOC has adopted theArtificial Intelligence Risk Management Framework (AI RMF 1.0) from NIST, which relates the potential risks to the aforementioned principles and rights. This approach makes it possible to determine which risks can endanger each of the families of fundamental rights, thus helping to anticipate and manage problems such as discrimination, privacy or security.

  • Step 3: Determination of risk management measures
    To identify the mechanisms and safeguards that may be more appropriate and effective in each case to avoid the violation of fundamental principles and rights, we have relied on Chapter II of the Ethical Guidelines for Trusted AI of the European Commission, and in the recently approved AI Regulation (mandatory application from 2/8/2026), so that the mechanisms are determined based on the level of risk of the AI ​​system and for certain AI systems or models. For example:
    • high risk: subject to specific safety and security requirements transparència, and the obligation to carry out an impact assessment relating to fundamental rights before deploying the system (art 27)
    • Limited risk: minimum obligations of transparència to allow users to make informed decisions and be aware when interacting with an AI.

This methodology helps us maintain an AI system that is transparent, secure and committed to protecting fundamental rights.

→ For more details, you can consult the full document: AOC AI Systems Risk Management Methodology (PDF)

→ At presentation (PPT, 7/11/2024) you can see a summary table of the three steps of the AOC's risk management methodology.

Published reports:

Status of the project

In ProductionFour reports have been published. transparència algorithmic.

More information

Practical cases implemented:

Cases in development phase:

Bibliographic references:

Legal obligations:

European framework

  • Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data and by which repeals Directive 95/46/EC (“GDPR Enllaç
  • Guidelines on automated individual decisions and profiling for the purposes of Regulation 2016/679. Adopted on 3 October 2017 and revised for the last time and adopted on 6 February 2018. Working Group on Data Protection Article 29 of Directive 95/46/EC. Enllaç
  • Regulation of the European Parliament and the Council establishing harmonized rules on artificial intelligence (AI Act) and certain legislative acts of the Union are modified. 12/7/2024. Enllaç 

State framework

  • Organic Law 3/2018, of December 5, on the protection of personal data and the guarantee of digital rights (“LOPDGDD Enllaç
  • Compliance with the RGPD of treatments that incorporate Artificial Intelligence. An introduction February 2020. AEPD. Enllaç
  • Law 15/2022, of 12 July, comprehensive for equal treatment and non-discrimination. Enllaç

Catalan framework

  • Law 19/2014, of December 29, of transparència, access to public information and good governance. Enllaç
  • Decree 76/2020, of August 4, on Digital Administration. Enllaç

[1] For example, the AI ​​Regulation specifies the information that must be provided in relation to certain AI systems (art 50); the GDPR determines the information that must be provided to the data subjectereswhen there are automated decisions (art 13); and the LRJSP establishes the obligation to inform about the body responsible for an automated administrative action in the electronic office, for the purposes of challenge (art 41).