Abstract

This chapter provides a comparative analysis of the regulatory, procedural, and infrastructural frameworks governing automated administrative decisions across eleven legal systems. It examines five core dimensions: definitional approaches, the existence of a general legal basis for automation, the sectors most affected by algorithmic decision-making, the procedural guarantees applicable to automated processes, and the nature of the actors and infrastructures that develop and support these systems. Despite significant heterogeneity, the comparison reveals the emergence of a shared set of procedural safeguards—transparency, participation, reasoning, traceability, and human oversight—adapted to the technical specificities of automation. At the same time, structural divergences persist, reflecting differing administrative cultures, regulatory philosophies, and political orientations. The chapter also highlights the decisive role played by data infrastructures and interoperability in enabling accountable automation. Ultimately, the analysis shows that automated administrative decision-making is reshaping the architecture of contemporary administrative law, generating both convergences and tensions that are essential to understanding the evolution of due process in the algorithmic age.

Table of Contents

1. Introduction

2. The definitional framework

3. Legal basis

4. Sectors most affected by automation

5. Procedural requirements
   5.1 Transparency
   5.2 Participation
   5.3 The duty to give reasons
   5.4 Human supervision

6. The nature of the entities that develop algorithms, infrastructure and interoperability

7. Conclusions