Victor Frimpong (SBS Swiss Business School) has posted Supervising Artificial Intelligence: Lessons from Established Supervisory Regimes for Direct, Delegated, and Hybrid Oversight on SSRN. Here is the abstract:
As artificial intelligence (AI) regulation moves from principles towards enforceable obligations, an important institutional question concerns who should supervise compliance and under what conditions. This study examines AI supervision as a problem of supervisory allocation, distinguishing the design of regulatory obligations from the institutional arrangements that monitor and enforce them. Using a qualitative, desk-based comparative case-study design, it analyses five established supervisory regimes: Swiss anti-money-laundering supervision, U.S. securities regulation, EU data protection, EU conformity assessment and market surveillance, and Indian securities-market self-regulation. The cases are compared across institutional dimensions including expertise, information access, independence, enforcement authority, adaptability, accountability, supervisory capacity, and exposure to capture or conflicts of interest. The analysis finds that no single supervisory architecture suits all functions. Delegation suits bounded and technically specialised tasks, while functions requiring coercive authority and heightened public accountability favour direct public involvement. Where technical expertise and statutory authority must operate together, hybrid arrangements become particularly relevant. Delegation also creates a secondary governance requirement: meta-supervision, whereby public authorities oversee delegated supervisors’ competence, independence, and performance. Building on these findings, the study develops the AI Supervisory Allocation Framework (ASAF) to assess the institutional fit of direct, delegated, and hybrid arrangements for specific supervisory functions. The study advances a functional approach to AI supervision by focusing on how supervisory responsibilities can be allocated based on a function’s requirements and the capabilities and constraints of the institutions involved.
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