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CriterIA© Observatory

AI without literacy, without reskilling and without governance does not scale productivity: it scales risk.

The CriterIA© Observatory measures twice a year which public AI-governance signals related to the EU AI Act can be seen from outside in a sample of Spanish organisations: SMEs and the wider business fabric, large companies, universities and schools, and public administrations. The Index is calculated only from the signals that the CriterIA© Radar observes automatically on corporate websites. What organisations declare voluntarily and anonymously in the CriterIA© 7, and the analyses they request with Huella de IA©, are recorded and published separately and never enter the Index. No organisation is named.

NEWAI Damage Report: the first cases on 20 November ‹

REGULATION (EU) 2024/1689 · ARTS. 4 AND 50 · FIRST EDITION ON 20·10·2026

CO-ORGANISED BY AEEN · Spanish Association of Business Schools EstratégicaMente
VENUE Next Educación
TAKING PART AESIA · Spanish Agency for the Supervision of Artificial Intelligence Edvolution Madrid Network

Data capture under way · closes 15 October 2026

 and rising

observations in the capture for the first edition, presented on 20 October in Madrid with AEEN

Figure for the period under way: it changes every few minutes. The last closed edition, which is the auditable one and is never recalculated, is shown below.

No percentage is published below one hundred observations: with fifteen, a single change moves the result by tens of points. It is an editorial rule, not a statistical one, and reaching one hundred does not turn a convenience sample into a representative one. We would rather be late than publish a figure that would not survive a question.

Exclusive preview · closed report figure

742of 761 with chat
give no notice

Of the 761 organisations with a conversational channel detected on their website, 742 give no notice that whoever answers may be an automated system. That is 97.5 %. Article 50(1) obliges the provider of the system to ensure the person knows they are talking to an AI: the signal is observed in the public channel, without prejudging who must remedy it.

This measures absence of public signal, not non-compliance: Article 50(1) obliges the provider of the system to design it so that it informs, and detecting a conversational channel does not prove that an AI answers it. The remaining figures, and the breakdown by the four sectors, are published with the first edition, presented on 20 October 2026 in Madrid with AEEN, with the sample closed on 15 October.

‹ Measure your organisation in 90 seconds Free · no sign-up · your answer joins the Observatory, not the Index

You can contribute your data — and learn where you stand — in ninety seconds.

Take the CriterIA© 7

Free · no sign-up · no email required · your answer joins the Observatory anonymously; it does not enter the Index

Methodology

Without literacy, reskilling and governance, AI can stop being a productivity tool and become a source of errors, uncritical dependence, poorly supervised decisions and loss of trust. It is what we have been arguing for more than two years and what the CriterIA© seal verifies: it trains the organisation's people, verifies seventy-nine points across eight dimensions and three pillars and issues a seal anyone can check without going through us. This indicator measures the public signal of the third; the other two are not visible from outside.

What this index measures and what it does not

The distinction matters more than the figures: what an organisation declares about itself and what is observed from outside are not the same thing.

What it does measure

  • Detected conversational channel — the website offers a chat, an assistant or a messaging link. It is the base for the notice and marking indicators, and it does not confirm that an AI answers.
  • Public transparency and governance signals that anyone can check by opening a website, without entering any private area.
  • Nothing else. The full list of dimensions, their calculation bases and the complete methodology are published with the first edition, on 20 October 2026. Announcing the definition early would mean correcting it in public if the capture changes it.

What it does not measure

  • It is not a legal opinion. It flags the absence of public signals, not a declared infringement.
  • It does not confuse exposure with non-compliance. Self-assessment only yields exposure: external observation can assess whether a notice is present, but not establish full compliance, since clarity, timing and accessibility also count.
  • It is not a probability sample of the Spanish economy. It is a convenience sample and is declared as such.
  • It identifies nobody. No domain, no email, no IP. The time window recorded is the month, not the instant.
  • It is not recalculated. Once an edition is published, its figures are frozen even if more responses arrive later.

Media, analysts or researchers? The data may be cited freely with attribution: «Criterion Index©, EstratégicaMente».

Ninety seconds · No sign-up

Contribute your data and learn your own

The CriterIA© 7 tells you where you stand on Articles 4 and 50. Your answer is added anonymously and in aggregate to the Observatory’s self-reported comparison. It does not enter the Index, which is based exclusively on externally observable signals.

Take the CriterIA© 7

How it works

Four doors, and none of them mixes with another

Three routes feed information into the Observatory, but only the Radar’s own sweep enters the Index. Huella de IA© and CriterIA© 7 are recorded and published separately, and each percentage is calculated on its own base. The fourth door brings no data. It is the one that explains why this Index measures only part of the problem.

Door 1 · CriterIA© Radar

External observation, without asking for anything. A crawler reads each organisation’s public pages: home page, assistant paths, legal notice, privacy and cookies. It respects robots.txt and stops when the site forbids it. Ingestion requires at least two readable pages; if it does not get them, the observation is discarded: it does not count as non-compliance, it counts as not observed. Each reading is labelled solid, minimal or limited according to the pages read, and limited readings are read again before each close.

Currently provides practically the whole sample

Door 2 · Huella de IA©

A complementary tool, not a data source. You enter your domain and get, for your own website, the analysis the Observatory runs on all of them: which signal is missing, on which page it was looked for, what the provision says and —what hardly anyone will tell you— whether that obligation is yours or your provider’s. It does not enter the Index: its purpose is to let each organisation see itself, and to serve as a test bench for the Radar itself. It is at huella.estrategicamente.info.

The most demanding engine of the three · does not enter the Index

Door 3 · CriterIA© 7

What you declare. Seven questions on Articles 4 and 50. A self-declaration only indicates exposure, never compliance: saying that your chat shows a notice does not prove that the notice is there. Only external observation proves that.

Never enters an observed indicator

Door 4 · What enters through no door

Adopting AI with judgement rests on three pillars, and this Index can see only one. Literacy: people knowing when not to believe the answer. Without it, the tool does not help to decide; it decides. Reskilling: redesigning jobs around what the person contributes. Without it, AI does not free up work; it hollows it out. Governance: which systems exist, who supervises each one and what trace is left. It is the only one of the three that leaves a public signal, and it is the one we measure.

The other two are verified with the CriterIA© seal, not from outside

And one rule that orders all of the above: each observation keeps the version of the detector that produced it. If the detector changes, new observations are not compared with old ones as if nothing had happened. A published edition is never recalculated; if a defect is found in the measuring instrument, the edition is withdrawn with a public erratum and a stated reason, and the original figures are kept intact.

Ninety seconds · No prior registration

Contribute your data and learn your own

The CriterIA© 7 tells you where you stand on Articles 4 and 50. Your answer is added to the CriterIA© Observatory anonymously and in aggregate, in the declared contrast. It does not enter the Index: that figure comes only from what can be observed from outside.

Take the CriterIA© 7

New monthly section of the CriterIA© Observatory

AI Damage Report

Real errors, real impact and the judgement to decide. Every month, cases from companies and education: what failed for lack of literacy, reskilling or governance, what it cost and what would have prevented it. The first report goes out on 20 November 2026.

AI Damage ReportCriterIA© Observatory · no. 001
01 · The error
What happened, without identifying the organisation.
02 · The consequence
What it cost in time, data, decisions, money, compliance or funding.
03 · The judgement
What should have been done and what we learn.
04 · The next step
A check to find out whether it is happening to you.
Observed factProven impactPotential riskRecommendation
First report
20 November

Technology hardly ever fails. What surrounds it does.

  1. Without literacy

    Nobody knows when not to believe the answer. The tool does not help to decide: it decides.

  2. Without reskilling

    Jobs are not redesigned around what the person contributes. AI does not free up work: it empties it.

  3. Without governance

    Nobody knows which systems exist, who oversees each one or what trace remains of what was decided.

Where we look

Companies

  • Operations
  • HR
  • Sales
  • Governance
  • Automation
  • Projects
  • Funding

Education

  • Universities
  • Training centres
  • Teaching
  • Assessment
  • Governance
  • Data
  • Accountability

Evidence, not anecdotes

Internally, every case carries its source, date, evidence and classification. We anonymise any sensitive information and check every regulatory statement against the version and date of the rule before publishing it.

The report does not feed the Índice de Criterio©: the index measures what can be seen from outside; the report tells what is already happening inside.

Could it be happening in your organisation?

Every edition ends with that question. Receive the report every month from 20 November, tell us about a case you know or check where you stand on Articles 4 and 50.

What to send us: a real AI error in a company or an educational institution, what it cost and what evidence exists. Where: at estrategicamente.info/en/send-a-case. No case is published without being anonymised.

If after reading it you need to review it with us, there is the CriterIA© Business Session, 45 minutes.

We do not analyse the AI that is announced. We analyse the AI that is already happening in organisations.

Who reviews this

An outside committee looks at the method before the figure comes out

A measurement that is published and cited cannot be reviewed only by whoever produces it. The Monitoring and Oversight Committee of the CriterIA© Observatory, made up of top-level professionals in law and regulation, business schools and universities, AI education and literacy, people and reskilling, public innovation and technology governance, and the digital economy, reviews the methodology and its limitations before each edition and records whether or not it endorses it. Disagreements are recorded in named minutes, and the minutes are published. Members who send no observations are recorded as “no observations received”, never as in agreement.

It is constituted by written adherence before 30 September 2026, and its membership, with the conflict-of-interest declarations of all its members, is published with the first edition.

First edition · 20 October 2026 · Madrid, with AEEN

Neither size nor sector explains anything

The usual objection is that SMEs lack the resources. We are also measuring those who have them. The breakdown by segment is published with the first edition, not before.

Four blocks, four separate series: universities and business schools, large companies and consultancies, SMEs and the rest of the business fabric, and public administrations. An SME follows Commission Recommendation 2003/361/EC: fewer than 250 employees; the block also includes organisations with no headcount data, and says so. Each block has its own index, and the overall Index is calculated on the joint population, not as an average of the four.

Analyses that cannot be completed due to crawler blocking are excluded from the calculation and do not count as non-compliance.

Presentation of the first edition

Join the presentation on 20 October

Tuesday 20 October, 12:00–13:30, at Next Educación (C/ Núñez Morgado, 5 · Madrid) and live online. Free of charge. The first edition of the Criterion Index© is published in the room, with the sample closed on 15 October.

Book a seat