AUTOMATION OF ADMINISTRATIVE PROCEEDINGS IN THE CZECH REPUBLIC: CRITICAL REFLECTIONS ON THE DRAFT “ADM AMENDMENT” TO THE ADMINISTRATIVE PROCEDURE CODE

This article examines the emerging regulation of automated administrative decision-making in the Czech Republic, with a focus on the recent proposal to introduce a new Section 15a into the Administrative Procedure Code. While the initiative reflects broader European efforts to digitalize public administration, it also exposes serious deficiencies in legislative technique, legal safeguards, and compliance with European law. The analysis situates the Czech debate against the background of existing domestic practices, such as algorithmic processing in tax administration and simplified enforcement mechanisms in traffic law, none of which presently authorize fully automated decisions. Using doctrinal analysis, critical regulatory assessment, and a targeted comparative perspective drawing on Sweden, Germany, and France, the article demonstrates that the Czech proposal fails to provide the necessary clarity, safeguards, and systemic preparation. It concludes that a responsible framework must be comprehensive, government-led, and accompanied by explicit criteria, robust safeguards, and institutional adaptation.