# Dutch Comfort: The limits of AI governance through municipal registers

arXiv: https://arxiv.org/abs/2109.02944 · HTML: https://mlsanity.com/paper/2109.02944/

## Key facts

- Cited by 4 papers in the map (data through 14 Oct 2026).
- Builds on 2 of its 44 references that are in the map.
- First posted on arXiv 7 Sep 2021.

## Builds on (most cited first, 2 of 2)

- [Decolonial AI: Decolonial Theory as Sociotechnical Foresight in Artificial Intelligence](https://mlsanity.com/paper/2007.04068/) (2020)
- [Combating Anti-Blackness in the AI Community](https://mlsanity.com/paper/2006.16879/) (2020)

## Built on by (most cited first, 4 of 4)

- [AI-Driven Document Redaction in UK Public Authorities: Implementation Gaps, Regulatory Challenges, and the Human Oversight Imperative](https://mlsanity.com/paper/2512.02774/) (2025)
- [A Critical Analysis of Trustworthy AI Tools, Mark Frameworks, and the Implementation Chasms](https://mlsanity.com/paper/2607.15480/) (2026)
- [Co-constructing sociotechnical AI governance: participatory system mapping using algorithm registers](https://mlsanity.com/paper/2608.12166/) (2026)
- [A Global Comparison of Schemas, Transparency, and Interoperability in Public-Sector AI Registers and Inventories](https://mlsanity.com/paper/2609.24883/) (2026)

## Abstract (arXiv)

In this commentary, we respond to a recent editorial letter by Professor Luciano Floridi entitled 'AI as a public service: Learning from Amsterdam and Helsinki'. Here, Floridi considers the positive impact of these municipal AI registers, which collect a limited number of algorithmic systems used by the city of Amsterdam and Helsinki. There are a number of assumptions about AI registers as a governance model for automated systems that we seek to question. Starting with recent attempts to normalize AI by decontextualizing and depoliticizing it, which is a fraught political project that encourages what we call 'ethics theater' given the proven dangers of using these systems in the context of the digital welfare state. We agree with Floridi that much can be learned from these registers about the role of AI systems in municipal city management. Yet, the lessons we draw, on the basis of our extensive ethnographic engagement with digital well-fare states are distinctly less optimistic.