What does the procedure do?
A description in sentences, not in model names: which decision is being prepared, on which data, within which limits.
Accountability
Responsibility and limits
Anyone using AI in dispatch must be able to answer two questions: who is liable when it gets it wrong — and what does it expressly not do? The second answer is the more credible one.
The questions
What a buyer wants to know today
These four questions now appear in almost every tender. Whoever cannot answer them is not screened out because of the AI, but because of the missing information.
Who decides?
At which point does a human step in, and can they overrule the result without bypassing the system?
What is logged?
Which proposal arose when and on what basis — and whether that can still be reconstructed afterwards.
Who is liable?
Who carries the decision when the proposal was wrong: the vendor, the operator, the user? That is a contractual question, not a technical one.
The architecture
What makes the answers easy
Traceability is not a documentation task at the end, but a design decision at the start. Three properties carry almost all the requirements.
Rules you can read
Radius, deadline, quota, price step: where a comprehensible rule decides, the explanation is the rule itself. A model explains itself less easily.
Results with provenance
Every value carries where it came from — measured, calculated or from a model. That is half the transparency obligation at the same time.
A human at the binding step
What is autonomous is the preparing and the asking. Whatever binds is confirmed by a person — and that step is in the log.
Context
What typically applies in transport planning
Most procedures in transport planning are not high-risk applications within the meaning of the Regulation: they are about loads, vehicles and prices, not about people. Two areas nevertheless deserve a close look — anything that assesses employees, and anything that automatically excludes business partners from orders.
And regardless of the classification, the transparency obligation applies: whoever speaks to a system must know that it is not a human. That is little effort and a lot of trust — and it is the point at which good vendors decided early.
This page is a practitioner's assessment and does not replace legal advice. What it is meant to do: ask the right questions early, while the answers are still cheap.
The clock
Deadlines that are fixed
Three deadlines are set. Each is listed here with the legal act it rests on.
- 9 July 2027 Electronic freight data Authorities in the EU must accept freight information provided electronically when it comes via a certified platform. Regulation (EU) 2020/1056 on electronic freight transport information.
- since 2 August 2026 Duty to disclose AI Anyone writing to or speaking with a system must be able to recognise that it is not a human. Regulation (EU) 2024/1689 on artificial intelligence, Article 50. Implemented on this portal: LENA says so in her first sentence.
- 2028 Carbon pricing in transport The start of the second European emissions trading system has been postponed from 2027; until then the national systems continue to apply. For costing and contracts that means: CO₂ clauses with scenarios instead of one fixed value.
As at 27 August 2026. Deadlines shift — the ETS2 start was once set for 2027. What stands here is the direction, not legal advice: anyone basing a decision on it should check the current status first.
The refusals
Six things we do not build
No AI in the award decision
Proposing yes, deciding no. An award commits money and carries a name — it belongs to a person, not in a model. What happens when this refusal is missing is worked through on a reverse auction.
No forecast without follow-up measurement
A prediction that nobody holds against reality is decoration. We deliver the follow-up measurement with it, or we do not deliver the forecast.
No estimated position in the field of a measured one
A calculated position goes in a field of its own. How it looks on the outside is a display question; that the program knows the difference is not.
No figure without provenance
Every value going out carries its method and source with it. Model values are marked as such — even when a round number would look better.
No chain built on someone else's capacity
Whoever has not committed does not get planned in. A chain built on an uncommitted carrier falls apart with the first refusal and blocks loads until then.
No procedure without comparison
A model that does not beat the existing planning is not progress — even if it sounds more modern and presents better.
The reason
Why this is not modesty
Every one of these refusals has been paid for dearly once — by us or by someone we watched. An estimated position that passed as a measured one made an empty run of over a thousand kilometres look like twelve. A check that reported “passed” on an internal error did the wrong thing unnoticed for days.
That is why there is a list of noes here instead of a list of yeses. Capabilities can be demonstrated; limits hold even when nobody is watching.
Direct Inquiry
Questions on liability and proof?
We go through the points that come up in a tender — and say where we say no.