Lobbying on Requirements for Artificial Intelligence

Requirements for Artificial Intelligence

Digital economy and society

While Artificial Intelligence (AI) is a strategic technology with tremendous opportunities, some of its uses pose specific significant risks relating to the application of various EU rules designed to protect fundamental rights, to ensure safety and to attribute liability. With this initiative, the EU will ensure that AI is developed and used in an appropriate legal framework with the overall goal to stimulate the up-take of trustworthy AI in the single market

Links

Public consultation

ID: 12527

Lobbying Activity

258 responses

Business lobby urges risk-based AI rules to avoid stifling innovation

BUSINESSEUROPE, 3 Aug 2020

The organization requests a narrow, risk-based approach covering only high-risk AI applications. They want new rules to apply exclusively to high-risk cases, not overlap with existing sector-specific regulations, and avoid requirements they view as impractical like demonstrating reproducibility or using only European training data.

This would limit compliance obligations to a narrow set of applications and preserve flexibility for AI development.

Consumer and civil society groups lose broader protections against AI harms beyond physical safety.

Google urges shared AI regulation responsibility with deployers

Google, 15 Jul 2021

Google requests creating a new class of "deployers" to share compliance obligations, especially for general-purpose AI tools. They argue providers often lack visibility into how systems are used and cannot fulfill requirements like post-market monitoring. The company also seeks clearer definitions and standards that reflect technical feasibility rather than perfection.

This would shield Google from liability when third parties deploy its APIs in high-risk applications.

Users lose protections when general-purpose AI tools are deployed in risky settings without provider oversight.

Google warns broad AI definitions risk stifling European innovation

Google, 9 Sept 2020

Google proposes a narrow definition of AI to protect innovation from unnecessary burdens. They advocate for a risk-based approach that relies on existing technology-neutral regulations. They suggest self-assessments and ex post enforcement instead of mandatory upfront reviews.

This approach would protect Google’s existing products from burdensome and costly new requirements.

Public safety and rights groups lose if regulations fail to cover all risky applications.

Consultation response

EUROPEAN TRADE UNION CONFEDERATION, 3 Sept 2020

IIA provides additional but still general information on options the EC intends to consider for legal act on AI. IIA still lacks to address the specificity of the workplace. Imbalance of power between employers and workers should lead EC to consider robust AI frame to create quality jobs, invest in…

Consultation response

Bureau Européen des Unions de Consommateurs, 5 Aug 2021

Please find BEUC's response to the consultation attached.

Consultation response

Bureau Européen des Unions de Consommateurs, 9 Sept 2020

BEUC welcomes the opportunity to comment on the Commission’s Inception Impact Assessment for the upcoming proposal for a legal act laying down requirements for Artificial Intelligence. BEUC particularly welcomes that the Commission – contrary to its White Paper published in February 2020 –…

Meta Urges EU to Refine Overbroad AI Act Definitions

Meta Platforms Ireland Limited and its various subsidiaries, 6 Aug 2021

Meta requests a narrower definition of AI to exclude basic software. They argue the requirement for error-free datasets is technically impossible. The company advocates for collaborative policy prototyping to develop practical standards.

A narrower scope would reduce Meta's compliance burden for everyday software.

EU regulators may face greater difficulty auditing complex AI without full transparency.

Microsoft urges principles-based approach for EU AI regulation

Microsoft Corporation, 6 Aug 2021

Microsoft requests a more flexible, principles-based regulatory framework that focuses on outcomes rather than prescriptive requirements. They advocate for creating new roles of 'technology supplier' and 'deployer' to better allocate responsibilities across the AI value chain. They also seek adjustments to requirements like data quality standards, arguing current obligations are unworkable for many AI scenarios.

This would reduce their compliance burden and allow continued innovation in AI services.

Users lose stronger data quality protections and clearer accountability from AI providers.

Microsoft urges risk-based AI regulation combining mandatory and voluntary measures

Microsoft Corporation, 10 Sept 2020

Microsoft requests a mixed regulatory approach with binding requirements only for high-risk scenarios like facial recognition in public spaces, combined with voluntary codes of conduct for lower-risk AI applications. They emphasize obligations should be carefully divided between AI developers and deployers based on context.

This would reduce compliance burden for their multi-purpose AI products used across sectors.

Citizens lose comprehensive protections as many AI systems would face only voluntary standards.

Consultation response

American Chamber of Commerce to the European Union, 23 Jul 2021

AmCham EU commends the European Commission for the extensive consultative process that led to the publication of the Proposal for an ‘AI Act’ . We appreciate having had the opportunity to provide our perspective on this important piece of legislation. We provided input to the AI White Paper…

Consultation response

American Chamber of Commerce to the European Union, 10 Sept 2020

The American Chamber of Commerce to the European Union (AmCham EU) has long called for a risk-based approach to artificial intelligence (AI) regulation, and fully supports the view that AI legislation must be targeted and focused on problems which are not already covered by existing…

Consultation response

Bundesverband der Deutschen Industrie e.V., 6 Aug 2021

Artificial Intelligence (AI) is one of the most important key technologies in industry. Therefore, unbureaucratic and innovation-friendly framework conditions for the use of AI are a central prerequisite for securing the innovation capacity and competitiveness of the German and European industry.…

Consultation response

Bundesverband der Deutschen Industrie e.V., 10 Sept 2020

The BDI welcomes the efforts of the European Commission to develop an appropriate ethical and legal framework based on the Union's values with the overriding goal to take on a global leading role in AI. A selective adaptation of the existing legal framework for AI can in-crease legal certainty for…

Consultation response

DIGITALEUROPE, 6 Aug 2021

Please find attached our detailed feedback, and a summary below. DIGITALEUROPE welcomes the European Commission’s legislative proposal for a Regulation laying down harmonised rules on artificial intelligence (‘AI Act’). We have been a key partner to EU institutions on AI topics for years, having…

Consultation response

DIGITALEUROPE, 10 Sept 2020

DIGITALEUROPE thanks the Commission for this opportunity to provide feedback on the AI Inception Impact Assessment. In our attached contribution, we analyse the various Options proposed by the Commission and give our comments and recommendations.

Consultation response

European Federation of Pharmaceutical Industries and Associations, 30 Jul 2021

EFPIA applauds the Commission for launching the first ever legal framework on AI that elaborates on a European approach for AI with an aim to promote Europe’s innovation and industry capacity in AI that could bring benefits to entire healthcare system. We welcome a risk-based approach to AI with an…

Consultation response

Volkswagen Aktiengesellschaft, 6 Aug 2021

Volkswagen AG very much welcomes the AI Act and its risk-based approach, and understands and supports the unique opportunity that the European Commission has in advancing the safe and trustworthy use of AI. We believe that this approach will give Europe a competitive advantage on the long-term…

Amnesty International demands ban on facial recognition and biometric surveillance

Amnesty International Limited, 6 Aug 2021

The organization demands an outright ban on facial recognition and remote biometric technologies enabling mass surveillance, third-party verification for all high-risk AI systems, and mandatory human rights due diligence. They seek stronger transparency, oversight mechanisms, and a complaints system for individuals harmed by AI.

This would protect their organizational mission of promoting human rights and preventing discriminatory surveillance practices.

Technology companies and law enforcement agencies lose flexibility to deploy biometric surveillance systems.

Consultation response

Deutscher Gewerkschaftsbund, 25 Jun 2021

Feedback Online Consultation EU Commission ARTIFICIAL INTELLIGENCE ACT 21 April 2021 In principle, the German Trade Union Confederation – DGB – welcomes that the EU Commission generally classifies AI systems as high-risk in the context of labour and employment as well as in education or…

Consultation response

Bayer AG, 29 Jul 2021

Mastering the new opportunities and challenges of innovation in life sciences is key for societies in the 21st century. One important element is a supportive policy and regulatory framework that fosters scientific advancement while at the same time ensuring trust and a high safety standard for…

Consultation response

ENEL SpA, 9 Sept 2020

Dear Members of DG CNECT .A.2, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a legal act laying down requirements for Artificial Intelligence. At Enel, we use Artificial Intelligence and technology to make the energy and power systems more…

Consultation response

Orgalim – Europe's Technology Industries, 10 Sept 2020

Orgalim strongly endorses the overall policy objective of ensuring the development and uptake of trustworthy AI across the Single Market. As this inception impact assessment outlines various options, Orgalim would like to affirm its support for Option 1 of the alternative options to the baseline…

Consultation response

IBM Corporation, 6 Aug 2021

IBM welcomes the opportunity to provide comments to the European Commission's draft Artificial Intelligence Act. We welcome the Commission’s risk-based approach to regulating specific uses of AI systems, not the AI technology itself. IBM believes certain aspects of the Regulation could be…

Consultation response

IBM Corporation, 19 Aug 2020

IBM welcomes the opportunity to respond to the Commission’s Inception Impact Assessment on the proposed legislative initiative on AI. We welcome the policy Objective and Aims of the initiative, in particular the intent to ensure coherence and complementarity with other possible initiatives, e.g.…

Consultation response

European Digital Rights, 3 Aug 2021

European Digital Rights (EDRi) is Europe’s biggest network defending rights and freedoms online. EDRi welcomes the European Commission’s globally significant step towards regulating the development and deployment of artificial intelligence systems. However, we would like to make suggestions to…

Consultation response

European Digital Rights, 9 Sept 2020

Aims: 1. EDRi argues that promoting AI uptake should not be an end in itself, rather a detailed framework to ensure all AI is lawful and fundamental rights compliant. Problem definition: 2. The definition of “remote biometric identification” is overly narrow. All mass surveillance uses of…

Consultation response

Insurance Europe, 6 Aug 2021

Insurance Europe welcomes the overall objective of the Commission to create a proportionate and principles-based horizontal framework of requirements that AI systems must comply with in the EU, without unduly constraining or hindering technological development and innovation. Moreover, insurers…

Consultation response

Orange, 29 Jul 2021

Orange’s preliminary position on the Artificial Intelligence Act Orange welcomes the opportunity to comment on the European Commission’s proposal for an Artificial Intelligence Act. This proposal, a first of a kind as highlighted by the EC, will have significant implications for AI ecosystems once…

Consultation response

Insurance Europe, 10 Sept 2020

Insurance Europe welcomes the initiative to encourage ethical and responsible development of AI in the EU and supports the creation of an ecosystem of trust to stimulate its uptake. A European approach is necessary to limit fragmentation of the digital single market, ensure fair competition and…

Consultation response

industriAll European Trade Union, 3 Aug 2021

IndustriAll Europe welcomes the European Commission’s draft regulation on AI, as it is the first proposal of its kind and will set new standards when it comes to addressing the challenges of high-end technology and human rights implications. We appreciate the opportunity to provide feedback on the…

Consultation response

Deutsche Industrie- und Handelskammer, 5 Aug 2021

The Association of German Chambers of Industry and Commerce (DIHK) welcomes the opportunity to provide feedback to the consultation on the proposal for the Artificial Intelligence Act. Artificial intelligence (AI) is considered to be one of the key technologies of digitalisation and a driver of…

Consultation response

Wirtschaftskammer Österreich, 22 Jun 2021

WKÖ-Positionspapier zum Rechtsrahmen für Künstliche Intelligenz Die technische Entwicklung schreitet voran und KI-Anwendungen finden immer vielfältigere Einsatzfelder, daher sind eigene einheitliche Regelungen grundsätzlich zu begrüßen. Um ein Level-Playing-Field zu garantieren, muss jedes…

Consultation response

Wirtschaftskammer Österreich, 10 Sept 2020

WKO Austria welcomes the opportunity to provide input to the Commission’s Inception Impact Assessment for the upcoming legislative framework on AI. We strongly believe, that it is very important to secure a future-proof framework that will support an innovative and competitive European market, and…

Nokia warns EU AI rules risk stifling European innovation

Nokia, 6 Aug 2021

Nokia requests narrower scope focusing on high-risk AI like deep neural networks rather than all computational techniques. They want clearer definitions of high-risk applications and feasible transparency requirements that don't mandate source code disclosure or impossible human oversight of systems operating at microsecond speeds.

This would reduce compliance costs and protect trade secrets while enabling continued AI development.

EU technology companies lose competitiveness against US and Chinese competitors facing lighter regulation.

Consultation response

European Association Automotive Suppliers, 8 Sept 2020

Automotive suppliers play a central role in the development of connected and automated vehicles. AI applications are becoming more and more common in cars: automated driving is the most well-known example, but a broad range of other applications are also concerned, such as many vehicle safety…

Consultation response

Eurocities, 27 Jul 2021

The Artificial Intelligence Act proposal is a crucial legislative initiative to create the conditions for a safe development and deployment of AI, based on European democratic values and in respect of people’s fundamental rights across Europe’s cities. AI is an enabler of change for local…

Consultation response

Eurocities, 10 Sept 2020

EUROCITIES welcomes the Inception Impact Assessment (IIA) on a proposal for a legal act laying down requirements for Artificial Intelligence (AI). AI is an enabler of change for local governments and is already transforming the governance of cities and society. As the level of governance closest…

Finance industry urges soft-law approach over AI regulation

Association for Financial Markets in Europe, 10 Sept 2020

AFME supports a voluntary, principles-based approach rather than mandatory AI-specific regulation. They argue existing financial services rules already address AI risks through consumer protection, conduct requirements, and operational resilience frameworks. Any new requirements should be limited to genuinely high-risk applications not covered by existing sectoral regulation.

This would avoid duplicative compliance costs and preserve their competitive position globally.

Citizens lose stronger protections if financial services exempted from high-risk designation.

European Banking Federation opposes new AI-specific legislation

European Banking Federation, 10 Sept 2020

The federation opposes new AI-specific legislation, preferring guidance from authorities on applying existing rules. They warn that prescriptive regulation could harm competitiveness and recommend technology-neutral approaches that avoid duplication with current financial sector regulation.

This would avoid additional compliance burdens and preserve banks' ability to innovate with AI.

Consumers lose stronger safeguards against AI systems not covered by existing financial regulation.

Consultation response

MedTech Europe, 10 Sept 2020

Artificial Intelligence (AI) in medical technologies has the potential to deliver on the promise of better healthcare in Europe. To optimise the value of AI in the healthcare sector, policies need to remain flexible and follow the evolution of technological development, allowing space for…

Consultation response

Mouvement des Entreprises de France, 22 Jul 2021

In a context of sovereignty and international competitiveness where the development of technological and digital infrastructures has become essential, it is vital to build a European ecosystem in favour of innovation and artificial intelligence (AI) that is respectful of European values. To build a…

Consultation response

Fortum Oyj, 10 Sept 2020

Fortum would like to see a regulatory framework for AI based on the following principles: Accountability should be the key element when creating an AI regulatory framework instead of creating exhaustive lists of sectors and critical use with demands of prior conformity assessments and approval.…

Consultation response

Mastercard Europe, 6 Aug 2021

Mastercard welcomes the opportunity to provide feedback to the European Commission on the Proposal for a Regulation laying down harmonised rules on artificial intelligence. This consultation comes at a difficult moment for many individuals, communities and businesses. Nearly a year and a half…

Consultation response

Mastercard Europe, 10 Sept 2020

Mastercard welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment (“IIA”) on an EU legislative initiative for AI. Mastercard wishes to express its support for Policy Option 4 as outlined in the IIA. We believe the Objectives highlighted by the IIA can…

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 6 Aug 2021

The Commission has come along with an ambitious proposal to regulate AI. Getting the balance right in ensuring that obligations drive policy outcomes, while allowing AI innovators sufficient flexibility in meeting those obligations, is going to be critical. Especially the ethical requirements will…

Connect Europe urges risk-based AI rules and voluntary labelling

Connect Europe, 10 Sept 2020

Connect Europe supports a risk-based approach combining voluntary labelling with limited mandatory requirements. They recommend avoiding sweeping regulatory interventions to protect innovation and industrial competitiveness.

Narrower regulations would reduce compliance costs and prevent delays in product launches.

Consumer protection groups lose broad oversight as mandatory rules target fewer applications.

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 10 Sept 2020

Technology Industries of Finland (TIF) represents more than 1,600 companies, active in Finland in various sectors of technology industries. Our member companies cover both developers and deployers of AI. Our main messages are: • There is no one, overarching AI. AI is a set of technologies for…

Consultation response

Société Générale, 29 Jul 2021

Please see the attached file

Huawei urges narrower AI definition and sector-specific oversight

Huawei Technologies, 5 Aug 2021

Huawei requests removal of statistical approaches and search methods from the AI definition, arguing they are too broad. They want sector-specific regulators to play the main role in AI oversight rather than creating new authorities. They also seek clarification on data completeness requirements and source code disclosure procedures.

This would reduce their compliance burden by excluding non-AI systems from regulation.

Consumers lose broader protections as more AI-adjacent systems escape regulatory oversight.

Huawei urges industry-led AI regulation over prescriptive rules

Huawei Technologies, 10 Sept 2020

Huawei requests tech-neutral risk assessment focused on scenarios rather than generic technologies, with industry-led self-regulation complementing formal rules. They advocate for multi-stakeholder governance and alignment with global standards rather than one-size-fits-all requirements.

This would reduce compliance costs and enable continued market access across jurisdictions.

Citizens lose stronger protections as industry self-assessment replaces independent regulatory oversight.

Consultation response

Ibec, 10 Sept 2020

Many thanks for the opportunity to comment. Please attached document.

Intel urges narrower AI Act scope for tech components

Intel Corporation, 6 Aug 2021

Intel requests removing statistical approaches and search methods from the AI definition, excluding toolkit and library developers from provider obligations, and limiting high-risk classification to systems with clearly safety-related intended uses.

This would exclude their general-purpose components and tools from provider compliance obligations.

Regulators lose broader oversight of AI components that could affect safety systems.

Consultation response

Novartis International AG, 5 Aug 2021

Novartis welcomes the European Commission's first-of-its-kind legislative proposal on the use of Artificial intelligence (AI), which positions the EU as leader in trustworthy AI and digital. As healthcare company, we use this innovative science to discover and develop medicines. AI technologies are…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 4 Aug 2021

Please find our position in the attached position paper.

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 10 Sept 2020

Please find the complette feedback of the GDV in attachment.

Consultation response

ITI - The Information Technology Industry Council, 6 Aug 2021

Please refer to the attached paper for ITI's detailed feedback to the proposal.

Consultation response

ITI - The Information Technology Industry Council, 10 Sept 2020

Please refer to the attached position paper for our detailed feedback.

DOT Europe urges flexible, risk-based approach to AI regulation

DOT Europe, 10 Sept 2020

DOT Europe requests a clear definition of high-risk AI to improve legal certainty. They argue regulatory oversight should target only the highest-risk applications. The group advocates for industry-led risk self-assessment combined with enforcement.

This approach avoids disproportionate obligations that would deter technological innovation.

European Disability Forum Calls for Stronger AI Safeguards and Accessibility Requirements

European Disability Forum, 28 Jul 2021

The organization requests mandatory accessibility requirements across all AI systems, bans on biometric identification in public spaces, and independent assessments of fundamental rights impacts. They want organizations of persons with disabilities involved in AI development and complaint mechanisms accessible to all.

This would protect their members from discriminatory AI systems and ensure accessibility features are built in from the start.

AI providers and surveillance operators lose ability to deploy biometric identification systems in public spaces.

Consultation response

The Danish Chamber of Commerce, 22 Jul 2021

The proposal uses a vague definition of artificial intelligence (AI) and it should be clearer how AI is used in different respects. In addition, the proposal relies to a great extent on the use of delegat-ed acts, which increases the uncertainty for the companies affected by the legislation, e.g.…

Consultation response

Bundesvereinigung der Deutschen Arbeitgeberverbände e.V., 28 Jul 2021

Please see our feedback attached.

Consultation response

E.ON SE, 5 Aug 2021

E.ON welcomes the opportunity to actively participate in the consultation process on the Artificial Intelligence (AI) Act. E.ON generally supports the plans of the European Commission to create a uniform framework for AI with the primary goal to strike a risk-based balance between the fundamental…

Consultation response

Associazione Bancaria Italiana, 2 Aug 2021

Il documento rappresenta il contributo dell'Associazione Bancaria Italiana (ABI) al dibattito in tema di Intelligenza Artificiale ed è stato redatto con l'attivo contributo dei gruppi di lavoro composti dalle banche associate e da esperti in materia. Nel ringraziare per l'opportunità, rimaniamo a…

Intesa Sanpaolo urges exemptions and clarity for banking AI regulation

Intesa Sanpaolo, 30 Jul 2021

The bank requests clearer integration with banking rules, exemptions for non-credit AI uses, and elimination of statistical approaches from the AI definition. They argue current requirements are technically impractical and excessively burdensome.

This would reduce compliance costs and avoid applying disruptive credit-lending rules to other banking operations.

Consumer protection weakens if banking AI systems face fewer bias-detection and transparency requirements.

APPLiA seeks narrower high-risk AI definition for appliances

APPLiA (Home Appliance Europe), 27 Jul 2021

The association requests that products are only labeled high-risk if their basic safety depends solely on AI. They also demand transparent criteria for when the Commission can bypass standard industry processes.

Narrowing high-risk classifications would reduce regulatory burdens and compliance costs for manufacturers.

Public safety oversight could be weakened for AI tools that perform secondary functions.

APPLiA urges voluntary approach rather than mandatory AI regulation

APPLiA (Home Appliance Europe), 10 Sept 2020

APPLiA opposes regulating AI because the concept is not well defined. They recommend a voluntary approach or limiting laws to specific categories.

A voluntary framework allows manufacturers to avoid strict compliance costs.

Citizens lose legal protections against risks like remote biometric identification.

Sanofi Calls for Centralized AI Authorization and Healthcare Exemptions

SANOFI, 22 Jul 2021

Sanofi requests a centralized authorization process for AI regulation with mutual recognition between authorities. They want existing healthcare surveillance mechanisms to be used for AI monitoring instead of creating duplicate reporting requirements. The company seeks to exclude traditional statistical methods and clinical evidence generation from the AI definition.

This would reduce compliance burdens and avoid duplicating existing pharmaceutical safety reporting systems.

Avaaz urges EU to expand AI risk assessments beyond high-risk categories

Avaaz Foundation, 6 Aug 2021

The organization requests compulsory risk assessment for all AI systems that could pose risks to health, safety, or fundamental rights, not just those in Annex III categories. They argue the tiered approach leaves mainstream AI development without ethical oversight and misses fundamental risks in apparently low-risk systems like content recommendation algorithms.

This would extend regulatory oversight to social media algorithms and other systems currently excluded from mandatory assessments.

Tech companies lose ability to deploy AI systems without external scrutiny or regulatory approval.

Consultation response

Johnson Johnson, 6 Aug 2021

Johnson & Johnson welcomes the opportunity to build a trustworthy and innovative ecosystem for artificial intelligence (AI), where the AI Act (AIA) plays a critical role in combination with the existing regulatory framework. The AIA should have a clear scope and framework, facilitating its…

Consultation response

EnBW Energie Baden-Württemberg AG, 23 Jul 2021

Aus Sicht der EnBW Energie Baden-Württemberg AG wurde mit dem Gesetzesvorschlag der EU-Kommission zu Künstlicher Intelligenz (KI), eine Regulierung entworfen, welche Chancen eröffnet. Nach erster Betrachtung, hiermit unsere erste kurze Rückmeldung aus energiewirtschaftlicher Perspektive sowie dem…

Consultation response

EnBW Energie Baden-Württemberg AG, 9 Sept 2020

As EnBW Energie Baden-Württemberg AG we welcome the approach of European Commission to conduct an Impact Assessment concerning ethical and legal requirements for AI. For several years already we have developed AI solutions in the energy sector. As operator and service provider in the field of…

Consultation response

France Industrie, 29 Jul 2021

Please find our position enclosed.

Consultation response

AstraZeneca PLC, 4 Aug 2021

AstraZeneca (AZ) welcomes the proposed draft Artificial Intelligence (AI) Act and believes that harmonised EU rules on AI can pre-empt a possible fragmentation of the single market and foster the safe and responsible development, use, and uptake of AI in the European Union. Tightening the…

Consultation response

Deutsche Börse AG, 6 Aug 2021

Dear Sir or Madame, please see the response of the Deutsche Börse Group attached. Best regards, Jan Doser

Consultation response

European Patients' Forum (EPF), 6 Aug 2021

EPF welcomes the EC’s endeavours to develop a European framework for artificial intelligence (AI) based on excellence, trust, human rights, and fundamental values. In healthcare, it is essential to adopt an approach aimed at ensuring the creation of an ethical, transparent, and trustworthy AI…

Sky urges refinement of AI Act definitions and requirements

Sky Group, 6 Aug 2021

Sky requests more precise definitions of AI systems, prohibited uses, and high-risk categories to avoid inadvertently capturing low-risk activities. They argue requirements like error-free datasets are not technically feasible and should be replaced with safeguards that minimize errors.

This would provide clarity to invest in innovation without burdensome compliance for low-risk AI applications.

Consultation response

BANCO BILBAO VIZCAYA ARGENTARIA, 5 Aug 2021

We welcome this opportunity to provide feedback to this important regulatory proposal that will undoubtedly influence the future development of AI in the EU. Although the proposed Regulation is quite balanced, we have identified some areas where there is room for improvement: Legal uncertainty.…

Consultation response

European Cancer Organisation, 6 Aug 2021

Because AI systems used in healthcare must be trustworthy and because lives and patients’ outcomes depend on it, the European Cancer Organisation recognises the necessity of a strong pan European framework to ensure the trustworthiness of AI in healthcare. The European Cancer Organisation therefore…

Consultation response

Business Software Alliance, 6 Aug 2021

Please find attached our position paper commenting on the AI Act Regulation proposal

Consultation response

Business Software Alliance, 10 Sept 2020

BSA would like to underline the need for the Commission to carry out an in-depth inventory of EU law, and its application to AI, before suggesting possible legislative actions. Consistent with the risk-based, context-specific approach of the White Paper, any proposed legislation should avoid…

Consultation response

Koninklijke Philips, 6 Aug 2021

Philips welcomes the opportunity to comment on the proposed AI Act. Please see our feedback attached.

Consultation response

Verband Kommunaler Unternehmen e.V., 6 Aug 2021

Der VKU bedankt sich für die Möglichkeit, zu dem Verordnungsvorschlag der Kommission über harmonisierte Regeln für künstliche Intelligenz Stellung zu nehmen. Wir begrüßen, dass die Kommission in ihrem Vorschlag einen risikobasierten Ansatz verfolgt. Damit bleibt die Mehrzahl der KI-Anwendungen…

Consultation response

Koninklijke Philips, 9 Sept 2020

Philips welcomes the opportunity to provide feedback on the roadmap for AI ethical and legal requirements. Please see our feedback in the attachment.

Consultation response

Infineon Technologies AG, 6 Aug 2021

Overall, Infineon Technologies AG welcomes the fact that the Commission has presented a risk-based approach aiming to regulate AI systems and their effects on economy and society. In our contribution to the upcoming discussion, Infineon focuses primarily on Article 3 (1) and Annex I – i.e. the…

German retailers urge EU to avoid new AI-specific laws

Handelsverband Deutschland, 9 Sept 2020

The HDE believes existing laws already provide sufficient consumer protection. They argue against new AI-specific legislation, preferring voluntary labels to maintain innovation. Any regulation must be strictly risk-based and protect proprietary trade secrets.

Retailers avoid high compliance costs and protect proprietary algorithms from public disclosure.

Individuals may face discrimination from biased data if specific regulatory safeguards are omitted.

German consumer group vzbv urges more consumer-centric AI Act

Verbraucherzentrale Bundesverband, 5 Aug 2021

The organization requests that the AI Act includes economic harms as high-risk and mandates individual explanations for consumers. They also advocate for banning dark patterns and emotion recognition by private companies.

This would empower consumer groups to proactively prevent harm and challenge discriminatory AI.

Companies using manipulative marketing or opaque insurance pricing would face significant regulatory restrictions.

Consultation response

European Tech Alliance, 23 Jul 2021

The European Tech Alliance welcomes the European Commission’s proposed AI Act as a good balance between supporting much needed AI innovation in Europe and having safeguards in place to ensure high safety standards and public trust in AI. We welcome the EU’s leadership in creating an AI regulatory…

Consultation response

European Tech Alliance, 10 Sept 2020

In February 2020, members of the European Tech Alliance (EUTA) joined forces to publish the EUTA High Level Principles on AI ahead of the publication of the European Commission’s White Paper on AI. EUTA members strongly believe the EU has the potential to become a world leader in AI. Europe…

vzbv Demands Mandatory EU Rules to Rebuild Consumer Trust in AI

Verbraucherzentrale Bundesverband, 8 Sept 2020

vzbv advocates for horizontal legislation covering all AI applications with mandatory transparency rules. They propose a gradual risk-based approach where risky systems are independently audited before market deployment. Consumers must receive clear explanations for specific automated decisions that affect their lives.

Stricter legal standards would increase public confidence and encourage widespread adoption of AI technologies.

AI developers would face higher costs due to mandatory testing and transparency requirements for all applications.

Consultation response

Finance Denmark, 13 Jul 2021

Finance Denmark supports regulation of AI. It is important to provide a regulation that protects the customer, through which trust in AI can be build. Much of what the financial sector does, is fundamentally based on trust. Therefore, it is important that AI-solution now and in the future can be…

Consultation response

Video Games Europe, 10 Sept 2020

ISFE represents the video games industry in Europe and is based in Brussels, Belgium. ISFE welcomes the opportunity to submit comments to the European Commission Inception Impact Assessment regarding the proposed policy options and instruments for Artificial Intelligence. Please find attached our…

Consultation response

Merck, 5 Aug 2021

Please see attached document.

Consultation response

European Confederation of Pharmaceutical Entrepreneurs, 29 Jul 2021

Representing small and medium-sized companies active in life sciences, EUCOPE acknowledges the Commission’s efforts in proposing a legal framework for Artificial Intelligence (AI). We particularly welcome the commitment from the Commission to strive for a balanced approach, as stated in the…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 6 Aug 2021

BVI welcomes the opportunity to provide its views on the European Commission’s proposal laying down harmonised rules on artificial intelligence. The use of artificial intelligence (AI) and machine learning (ML) in asset management bears great potential. An increasing degree of automation of…

U.S. Chamber of Commerce urges flexible, risk-based AI rules

Chamber of Commerce of the United States of America, 6 Aug 2021

The organization requests a narrower AI definition and a flexible, outcome-oriented approach. They propose limiting regulator access to sensitive trade secrets like source code and data sets. Additionally, they advocate for international alignment to ensure transatlantic regulatory interoperability.

This approach would reduce significant compliance costs and protect proprietary technology from disclosure.

Public authorities and consumer groups may lose the ability to independently verify algorithms for bias.

Consultation response

European Association of Co-operative Banks, 23 Jul 2021

The European Association of Co-operative Banks (EACB) recognises that the AI proposal is the Commission’s first ever legal framework on the matter, which addresses the risks of AI and aims to position Europe to play a leading role globally. It should be recognised that this is a risky bet. If…

Consultation response

Workday, 3 Aug 2021

Workday’s response to the European Commission’s proposal for regulation on artificial intelligence (the AI Act) draws on our contributions to the Commission’s preparatory consultations as well as earlier work developing Ethics Guidelines for Trustworthy AI. We highlight important areas of alignment…

Consultation response

Workday, 10 Sept 2020

Please find attached Workday's comments on the Inception Impact Assessment Best regards, Jens-Henrik Jeppesen Director, Public Policy, EMEA

Consultation response

Association of the European Self-Care Industry, 6 Aug 2021

AESGP welcomes the European Commission’s effort to develop a European approach for artificial intelligence (AI) that promotes Europe’s innovation capacity while ensuring the creation of an ethical and trustworthy AI. If properly addressed, AI could bring tremendous benefits to the healthcare sector…

Consultation response

Access Now Europe, 5 Aug 2021

Access Now welcomes the European Commission’s pioneering proposal for a regulatory framework for artificial intelligence. We have consistently pointed to the insufficiency of ethics guidelines and self-regulatory approaches, and have long called for regulatory intervention in the field of AI. The…

Consultation response

Access Now Europe, 8 Sept 2020

Access Now opposes the uptake of AI as an objective for a potential regulatory intervention. Our opinion on a legislative proposal will be based on the assessment of whether it ensures adequate safeguards for the protection and promotion of fundamental rights including societal impacts. All points…

Consultation response

Computer & Communications Industry Association, 10 Sept 2020

The Computer & Communications Industry Association (CCIA) welcomes this opportunity to respond to the European Commission’s inception impact assessment on Artificial Intelligence (AI). We support the Commission’s aim to “create trust and incentivise the use of such AI systems by citizens and…

Consultation response

RELX, 5 Aug 2021

RELX welcomes the opportunity to provide feedback on the European Commission’s proposed regulation on Artificial Intelligence (AI). The regulation sets out how the Commission wishes to develop harmonised rules on AI and will have a significant impact on the future development and use of AI systems…

Consultation response

Liberty Global Corporate B.V., 5 Aug 2021

Liberty Global welcomes the opportunity to comment on the European Commission (EC)’s consultation of the proposal for a Regulation laying down harmonized rules on artificial intelligence (the proposal) and its annexes. In previous submissions, Liberty Global supported the EC’s comprehensive…

Medical technology group warns AI Act burdens healthcare innovation

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 2 Jul 2021

COCIR urges removing medical devices from the high-risk category to avoid regulatory duplication. They recommend aligning definitions with medical laws and relaxing data accuracy requirements. The group also requests extending the transition period to four years.

This would reduce compliance costs and prevent redundant regulatory hurdles.

Patients may suffer if developers prioritize other markets with faster approval processes.

COCIR urges EU to use existing medical device rules for AI

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 10 Sept 2020

COCIR argues against new regulatory frameworks for AI-based medical devices. They believe current medical and data protection rules already ensure safety, and suggest using voluntary codes and international standards instead.

The industry avoids the administrative costs and complexity of complying with new, overlapping regulations.

Patients may face inconsistent safety standards if ethics oversight remains voluntary rather than mandatory.

Consultation response

RELX, 10 Sept 2020

RELX welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment (IIA) for a legislative initiative on artificial intelligence (AI). Below are our comments on the legislative options outlined in the IIA. Option 0 / baseline Before any new policy…

Consultation response

Standing Committee of European Doctors, 6 Aug 2021

Dear Madam/Sir, Please find attached in pdf the CPME Feedback on Commission Proposal for a Regulation on Artificial Intelligence. Kind regards, Annabel Seebohm Annabel Seebohm, LL.M. (Auckland) Secretary General Comité Permanent des Médecins Européens Standing Committee of European Doctors 15…

Consultation response

Suomen Yrittäjät ry, 21 Jun 2021

The proposal for the Artificial Intelligence Act has admirable objectives but is riddled with issues, which render the regulation problematic. Despite containing some right elements, the proposal is excessively burdensome from the perspective of smaller European enterprises developing,…

Consultation response

Centre for Democracy Technology, Europe, 3 Aug 2021

The Centre for Democracy & Technology, Europe (CDT) welcomes the EU AI Act and the high priority it aspires to give to protecting fundamental rights. All AI systems should be subject to a human rights impact assessment and subject to regulation proportionate to the risks identified in that…

Consultation response

Ingka Services A.B., 10 Sept 2020

Since 2018, Ingka Group, the strategic partner in the IKEA franchise system, has embarked on a journey to transform our company into a retailer fit for the 21st century. We are becoming data-driven, using digital tools such as Artificial Intelligence (AI) to meet customers wherever and whenever…

Consultation response

LA POSTE, 6 Aug 2021

Selon Le Groupe La Poste, le Hub France IA et la Villa Numeris, l’intelligence artificielle (IA) ouvre des possibilités multiples pour l’innovation et la croissance et nous souhaitons saisir tout son potentiel. Le Groupe La Poste, qui place le numérique et l’IA parmi ses axes prioritaires et…

Consultation response

European Savings and Retail Banking Group, 5 Aug 2021

Please find attached the ESBG feedback on the European Commission's draft Artificial Intelligence Act.

Consultation response

DIN Deutsches Institut für Normung e. V., 15 Jun 2021

We welcome the European Commission's proposal for a regulation that focuses on trustworthiness and product safety of high-risk artificial intelligence (AI) for the European Single Market. AI technology will only be used across the board if it is trustworthy and finds acceptance in society.…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 6 Aug 2021

ZVEI welcomes the ambitious goal of the EU-Commission to promote and facilitate the uptake of Trustworthy AI in Europe. The EU-Commission puts forward a proposal for a harmonised European approach addressing potential risks and uses of AI applications. We plead to also focus on the immense…

Consultation response

Deutscher Anwaltverein (German Bar Association), 6 Aug 2021

Siehe vollständige SN in der PDF-Datei. 1. Grundsätzlicher Ansatz der Regulierung Der grundsätzliche Ansatz der Regulierung in Form einer horizontalen Regulierung sowie die Grundpfeiler für hochriskante KI-Systeme sind zu begrüßen, namentlich: - eine verstärkte Verpflichtung zum Qualitäts- und…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 9 Sept 2020

The Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (ZVEI) welcomes the opportunity to provide feedback to the Inception Impact Assessment of the European Commission for a proposal for a legal act of the European Parliament and the Council laying down requirements to stimulate the…

App Association urges EU to ease AI compliance burdens on small businesses

ACT | The App Association, 3 Aug 2021

The organization requests a narrower definition of high-risk AI, exemption of research from requirements, and maximum four-week approval timeframes. They argue current compliance costs of up to €330,000 upfront plus €71,400 yearly are unrealistic for small companies.

This would reduce massive compliance costs and speed market access for their small business members.

Consumer protection may weaken if oversight requirements and risk assessment obligations are reduced.

Consultation response

European Federation of Investors and Financial Services Users, 6 Aug 2021

Please see document attached

Consultation response

MFE - MEDIAFOREUROPE N.V, 5 Aug 2021

see attached file

Consultation response

Siemens Healthineers AG, 6 Aug 2021

Siemens Healthineers welcomes the initiative of the European Commission to set a global benchmark for deployment of ethical and legal artificial intelligence (AI) applications. AI has already brought numerous advancements to the field of healthcare by providing assistance to medical professionals…

Consultation response

5Rights Foundation, 3 Aug 2021

5Rights Foundation warmly welcomes the aims of the AI Act to ensure the development, marketing and use of artificial intelligence in conformity with Union values and a high level of protection of health, safety and fundamental rights. In particular the provisions in Recital 28, Article 5.1 and…

Consultation response

ABB Ltd, 6 Aug 2021

ABB welcomes the opportunity to comment on the European Commission proposal for a Regulation laying down harmonised rules on Artificial Intelligence (“AI Act”). The AI Act is an important step towards the ambitious goal to promote and facilitate the uptake of trustworthy AI in Europe. We believe…

Finnish research center urges flexible AI Act to avoid stifling innovation

CSC – IT CENTER FOR SCIENCE LTD., 9 Jul 2021

The organization requests generic AI definitions that regulate purposes rather than technologies, and clearer requirements for high-risk systems. They argue technology-specific definitions quickly become outdated and create loopholes, while vague terms like 'psychological harm' allow arbitrary interpretation.

This would allow their research activities to continue without barriers from outdated definitions.

Consultation response

Visa Europe, 10 Sept 2020

Please see attached file.

Consultation response

World Employment Confederation-Europe, 6 Aug 2021

Main points: - WEC-Europe welcomes the creation of a regulatory framework of AI that will improve predictability and a level playing field for the application of AI. - Following its Code of Conduct, WEC-Europe is dedicated to improving labour market inclusiveness and fighting (un)conscious human…

STM Publishers Seek Narrower AI Definitions and Intellectual Property Protection

International Association of Scientific, Technical and Medical Publishers, 30 Jul 2021

The association argues that the proposed definitions for AI and high-risk systems are currently too broad. They request that new regulations do not override existing intellectual property rights or sector-specific rules. The group also advocates for prioritizing industry-led standards and providing funding for community-developed initiatives.

This would preserve their control over data assets and minimize new compliance costs.

European researchers face stifled innovation if new rules are overly rigid or redundant.

STM Publishers urge EU to avoid premature AI legislation

International Association of Scientific, Technical and Medical Publishers, 9 Sept 2020

STM recommends building on existing laws instead of introducing premature new legislation. They also request funding for content owners to provide high-quality training data.

This strategy reduces compliance costs while securing financial support for their datasets.

Consultation response

Fédération Française de l'Assurance, 6 Aug 2021

The French Insurance Federation (FFA) supports the implementation of a framework for an ethical use of AI: human-centric, unbiased, transparent, and explainable. French insurers welcome the Commission's proposal for a risk-based regulatory framework with differentiated rules according to the risks…

Consultation response

Atos SE (France), 8 Sept 2020

Artificial intelligence – ethical and legal requirements Atos Feedback – 8 Sep 2020 Atos welcomes the opportunity to respond to the Inception Impact Assessment proposed by the European Commission on the proposed legal act on Artificial Intelligence. Atos supports implementing policies aiming at…

Consultation response

The Guild of European Research-Intensive Universities, 16 Jul 2021

Founded in 2016, The Guild comprises twenty one of Europe’s most distinguished research-intensive universities in sixteen countries, and is dedicated to enhancing the voice of academic institutions, their researchers and their students. The Guild is committed to the pursuit of excellence, the…

Consultation response

Allied For Startups asbl, 13 Jul 2021

AFS Feedback to the European Commission’s regulation proposal on the Artificial Intelligence Act Artificial Intelligence has the potential to solve some of the world’s biggest challenges, ranging from combating climate change to improving people’s everyday lives. Startups are at the forefront of…

Consultation response

Thorn, 3 Aug 2021

Thorn welcomes the opportunity to provide feedback on the Commission's proposal for artificial intelligence regulation. Thorn is a US-based nonprofit organization that builds technology to defend children from sexual abuse and online exploitation. At Thorn, we believe in the power and potential of…

Consultation response

Pharmaceutical Group of the European Union, 20 Jul 2021

The Pharmaceutical Group of the European Union (PGEU), the organization representing community pharmacists in 32 European countries, welcomes the European Commission’s Proposal for an EU Regulation on Artificial Intelligence (AI) to establish a legal framework on AI Systems. Please find the full…

Consultation response

Pharmaceutical Group of the European Union, 10 Sept 2020

The Pharmaceutical Group of the European Union (PGEU), the organization representing community pharmacists in 32 European countries, welcomes the European Commission’s Roadmap aimed at addressing a number of ethical and legal issues raised by Artificial Intelligence (AI). We support the…

Consultation response

Commissariat à l'Energie atomique et aux énergies alternatives, 8 Sept 2020

CEA welcomes the opportunity to provide feedback on the Commission’s Inception Impact Assessment for a European legal act aimed at addressing the ethical and legal issues raised by AI. We welcome the initiative objectives, in particular the intention to create a harmonised framework in order to…

Consultation response

DEKRA e.V., 8 Jul 2021

As an independent Testing, Inspection and Certification (TIC) company, we welcome the European Commission’s proposal for a Regulation laying down harmonized rules on Artificial Intelligence to ensure the safety and security of European consumers in the area of Artificial Intelligence. Third-party…

Consultation response

Svaz průmyslu a dopravy ČR, 10 Sept 2020

Please find attached

Consultation response

AGORIA, 29 Jul 2021

Full position as attachement First, Agoria suggests refining the scope, by adjusting the proposed definition of AI systems, the classification of identified high-risk AI applications and the allocation of roles. The scope of the regulation is essential, requiring clear definitions that are easily…

Consultation response

AGORIA, 10 Sept 2020

“Agoria is the Belgian federation for the technology industry. We are paving the way for all technology-inspired companies in Belgium pursuing progress internationally through the development or application of innovations and which, together, represent some 300,000 employees. We are proud that more…

Consultation response

Future of Life Institute, 6 Aug 2021

The Future of Life Institute (FLI) welcomes the opportunity to provide feedback on the proposal for a Regulation of the European Parliament and of the Council laying down harmonised rules on artificial intelligence (Artificial Intelligence Act). FLI recommends that a final Act i) accounts for the…

Consultation response

Japan Business Council in Europe, 6 Aug 2021

JBCE welcomes the European Commission’s attempt to set a horizontal Regulation for trustworthy AI with the AI Act. In this context, JBCE asks for a clear definition of AI to ensure an effective and harmonized interpretation and enforcement of the Act. We encourage continued work with…

Consultation response

Związek Pracodawców Business & Science Poland, 5 Aug 2021

Business & Science Poland (BSP) welcomes the possibility to comment on the proposal for a Regulation of the European Parliament and of the Council on laying down harmonized rules on Artificial Intelligence (Artificial Intelligence Act) and amending certain union legislative acts (COM (2021) 206…

Consultation response

Bundesarbeitskammer Österreich, 4 Aug 2021

Dear Madam, Dear Sir, Enclosed you will find the statement from the Vienna Chamber of Labor. The Federal Chamber of Labor (BAK) is the legal representation of the interests of around 3.7 million employees and consumers in Austria. It represents its members in all social, educational, economic and…

Consultation response

European Trade Union Committee for Education, 30 Jul 2021

The European Trade Union Committee for Education (ETUCE), Social Partner in education at the EU level, representing 127 Education Trade Unions and 11 million teachers in Europe, welcomes the Commission’s proposal for the AI Regulation as it sets the ground for the first comprehensive EU regulation…

Consultation response

The European Consumer Voice in Standardisation, 13 Jul 2021

Please find attached ANEC's comments.

Consultation response

CEMA - European Agricultural Machinery Industry Association, 10 Sept 2020

CEMA considers the initiative from the European Commission to deal with ethical and legal requirements on AI must be coordinated to take into account: - Initiatives already initiated, for example the revision of the Machinery Directive to take into account new technologies - Initiatives initiated…

Consultation response

Japan Business Council in Europe, 10 Sept 2020

JBCE welcomes the European Commission’s efforts to establish a common European approach to AI. This will help the EU’s AI market reach scale and avoid legal uncertainty or fragmentation of multiple policies among EU Member States, through protecting our safety, consumer rights and fundamental…

Consultation response

The European Consumer Voice in Standardisation, 31 Aug 2020

As the European Commission’s assessment of product safety and liability legislation shows, there are gaps in present legislation and new AI related aspects such as explicability require new legal provisions, especially for enforcement purposes. We therefore support Option 3.c: EU legislative…

Consultation response

Fair Trials Europe, 10 Sept 2020

Fair Trials is aware that the Inception Impact Assessment considers the entire and wide array of economic and societal issues in relation to AI across a spectrum of industries and social activities. However, this response is concerned specifically with AI in the context of criminal justice and will…

Consultation response

Federation of European Data and Marketing, 10 Sept 2020

FEDMA previously answered the consultation on the white paper on AI. We would like to share the below insights: • The work of the High-Level Expert Group on criteria for risk assessment and the feedback that they are receiving from the industry should be considered. • Self-learning systems are…

Consultation response

European Society for Medical Oncology (ESMO), 6 Aug 2021

The European Society for Medical Oncology (ESMO) welcomes the proposal for a Regulation laying down harmonised rules on Artificial Intelligence. While the intention of the Regulation is welcomed, ESMO is concerned regarding the potential impact of this Regulation on the usage of artificial…

Consultation response

Association française des sociétés Financières, 2 Aug 2021

L’Association française des Sociétés Financières (ASF) représente les métiers de financement spécialisé en matière de crédit ainsi que les services financiers et d’investissement. Les établissements membres de l’ASF financent plus de 20 % des crédits au secteur privé. Observations liminaires…

Consultation response

Civil Liberties Union for Europe, 14 Jul 2021

The Civil Liberties Union for Europe (www.liberties.eu) welcomes the opportunity to provide feedback to the AI Regulation proposal. We recognize that Artificial Intelligence (AI) can contribute positively to our societies. But AI systems can also undermine our fundamental rights, by perpetuating…

Consultation response

The Future Society, 6 Aug 2021

The Future Society (TFS) is a global nonprofit advancing the responsible adoption of Artificial Intelligence (AI) for the benefit of humanity. With a network of policy researchers and practitioners in the EU, the US and all over the world, we build understanding of AI and its impact, we build…

Consultation response

Standard Chartered, 5 Aug 2021

Please see attached feedback from Standard Chartered.

Consultation response

TÜV-Verband e. V., 5 Aug 2021

Der TÜV-Verband begrüßt die Initiative der Europäischen Kommission, ein verbindliches Rahmenwerk zur Regulierung von Systemen, die auf dem Einsatz Künstlicher Intelligenz basieren, zu schaffen. Ein robuster Regulierungsrahmen ist die Grundvoraussetzung für das notwendige Vertrauen der Menschen in…

Consultation response

The European Association of Hospital Pharmacists, 2 Aug 2021

The European Association of Hospital Pharmacists (EAHP) welcomes this legislation proposal on the ethical and legal requirements on Artificial Intelligence (AI). The proposed regulation lays down a set of harmonised rules for the development, placement on the market and use of AI systems in the…

Consultation response

TÜV-Verband e. V., 10 Sept 2020

The Association of German Technical Inspection Agencies (Verband der TÜV e.V.) welcomes the Commissions Inception Impact Assessment and would like to provide feedback on the core issues raised. Artificial Intelligence (AI) is a fast evolving technology that can create significant economic and…

Consultation response

Die Deutsche Kreditwirtschaft, 6 Aug 2021

Dear Sir or Madam, Please find enclosed the statement of the German Banking Industry Committee on the European Commission's proposed regulation on the regulation of artificial intelligence (AI act). Sincerely, Dr. Wiebke Lüke

Consultation response

Twilio Inc., 6 Aug 2021

Twilio welcomes the opportunity to engage further with the European Commission on its proposal regarding appropriate rules for the use of Artificial Intelligence (AI). Twilio has already submitted a response to the European Commission’s White Paper on Artificial Intelligence – A European Approach…

Consultation response

F. Hoffmann-La Roche Ltd, 30 Jul 2021

PLEASE SEE ATTACHMENT FOR FULL RESPONSE AND COMMENTS

Consultation response

Twilio Inc., 10 Sept 2020

Twilio thanks the European Commission for the opportunity to respond to the Inception Impact Assessment on developing requirements for Artificial Intelligence. Twilio has already submitted a response to the European Commission’s White Paper on Artificial Intelligence – A European Approach where the…

Consultation response

CECE - Committee for European Construction Equipment, 9 Sept 2020

CECE welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on a proposal for a legal act laying down requirements for Artificial Intelligence. Regarding the different policy options proposed, we would like to share the following comments: - POLICY OPTION…

Consultation response

Bundesärztekammer, 8 Sept 2020

Comments by the German Medical Association (Bundesärztekammer): Further to our response to the public consultation on the White Paper on Artificial Intelligence (AI), the German Medical Association would like to comment on the Inception Impact Assessment: Regulatory options The Inception Impact…

Consultation response

5G Automotive Association, 6 Aug 2021

The 5G Automotive Association (5GAA) welcomes the opportunity to provide feedback on the Artificial Intelligence Act and share our recommendations to help the EU adopt future-proof legislation accelerating the market entry of connected and automated vehicles and smart mobility services while…

Consultation response

ACCIS, 4 Aug 2021

The Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies in the world. ACCIS brings together 40 members across 28 European countries and 11 associate and affiliate members from all other continents. Building on the vast experience…

Consultation response

Wikimedia Europe, 3 Aug 2021

Wikimedia operates a number of online platforms that offer access to and re-use of the world's largest freely available datasets. These are used widely as training data for machine learning algorithms. Wikimedia also develops and operates machine learning algorithms, mainly with the goal to make…

Consultation response

Keidanren (Japan Business Federation), 10 Sept 2020

The feedback by AI Utilization Strategy Task Force, Committee on Digital Economy, Keidanren is over 4000 characters. Please find attached file.

Consultation response

Związek Przedsiębiorców i Pracodawców, 5 Aug 2021

ZPP od dawna podkreślał, że przygotowanie adekwatnej regulacji w zakresie sztucznej inteligencji będzie wyjątkowo wymagającym zadaniem. Z jednej strony bowiem oczywistym celem regulatora jest zabezpieczenie obywateli i podmiotów gospodarczych przed nieetycznym stosowaniem technologii AI, z drugiej…

Consultation response

European Association of Communications Agencies, 15 Jul 2021

The European Association of Communications Agencies (EACA) represents more than 2,500 communications agencies and agency associations from nearly 30 European countries that directly employ more than 120,000 people. EACA members include advertising, media, digital, branding and PR agencies. We…

Consultation response

Związek Przedsiębiorców i Pracodawców, 10 Sept 2020

First, we would like to highlight the risks arising from the extension of the scope of future AI Regulation to automated decision making. Such inclusion would stand in opposition to the fundamental ideas laid out on the White Paper on Artificial Intelligence, which proposed to adopt a risk-based…

Consultation response

Algemeen Christelijk Vakverbond van België, 8 Sept 2020

The ACV-CSC-Belgium Congress on the Future of Work - #Arbeidmorgen, #Queltravaildemain, #Arbeitmorgen - gathered in October 2019 more than 850 delegates for the adaption of its final conclusions. Thousands of members of ACV-CSC-Belgium participated before in a process of preparation and elaboration…

Consultation response

European Association of Communications Agencies, 4 Aug 2020

EACA welcomes the opportunity to give feedback on this roadmap where we would like to reiterate the points made during the Commission’s public consultation on its White Paper on Artificial Intelligence: On the trustworthy use of Artificial Intelligence From our industry’s point of view,…

Consultation response

Application Developers Alliance, 4 Aug 2021

Developers Alliance welcomes the opportunity to provide feedback on the AI Act proposal. We commend the objectives and the risk-based approach of the proposal. We call on the EU co-legislators, however, to address a series of critical issues so the regulation will be fit for purpose and to reduce…

Consultation response

WithSecure Corporation, 10 Sept 2020

F-Secure is very happy to see the discussion on ethical and legal requirements of AI progressing, as this is an important topic and a core part of the EU position towards AI. One fundamental aspect we fully agree with is having EU level approach instead of country-specific ones. We are happy to…

Consultation response

Application Developers Alliance, 10 Sept 2020

Developers Alliance welcomes the opportunity to further provide feedback on the European Commission’s proposals on requirements for AI. The Inception Impact Assessment presents several regulatory options and the underlying policy objectives, based on the approach initiated by the White Paper on…

Consultation response

Hutchison Europe - Brussels Branch, 8 Sept 2020

Please see attached document.

Consultation response

Global Legal Entity Identifier Foundation, 6 Aug 2021

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission's Proposed EU Artificial Intelligence Regulation. GLEIF will focus its comments on how using the Legal Entity Identifier (LEI) in the AI framework can enhance traceability and…

Consultation response

Medtronic, 6 Aug 2021

Please find our feedback attached.

Consultation response

Move EU - The European Association of On-Demand Mobility, 5 Aug 2021

Move EU welcomes the European Commission’s ambitious proposal for an AI Regulation and the opportunity to provide feedback on behalf of its member companies in the on-demand mobility sector. Move EU brings together the leading actors in the field of ride-hailing services. Speaking with one voice,…

Consultation response

Numeum, 26 Jul 2021

Numeum soutient la Commission européenne dans son ambition de stimuler le développement et l'adoption de l'IA et des nouvelles technologies, tout en veillant à ce que les risques potentiels soient traités de manière adéquate. La volonté de la Commission de créer un système européen à même de…

Consultation response

Science Europe, 10 Sept 2020

Science Europe welcomes the opportunity to react to the European Commission’s (EC) Inception Impact Assessment for a ‘Proposal for a legal act laying down requirements for Artificial Intelligence’. Science Europe Member Organisations, major national research funding (RFOs) and performing…

Consultation response

Numeum, 10 Sept 2020

Syntec Numérique soutient la Commission dans son ambition de stimuler le développement et l'adoption de l'IA et des nouvelles technologies, tout en veillant à ce que les risques potentiels soient traités de manière adéquate. Afin de garantir la cohérence avec la législation sectorielle existante,…

Consultation response

Federation of European Risk Management Associations, 10 Sept 2020

The Federation of European Risk Management Associations (FERMA) welcomes the opportunity to comment on the Commission’s Inception Impact Assessment, specifically on the relevant policy options and policy instruments in the area of Artificial Intelligence. Our input here is complemented by our…

Consultation response

Bundesverband Digitale Wirtschaft (BVDW) e.V., 6 Aug 2021

Der Bundesverband Digitale Wirtschaft (BVDW) e.V. ist die Interessenvertretung für Unternehmen, die digitale Geschäftsmodelle betreiben oder deren Wertschöpfung auf dem Einsatz digitaler Technologien beruht. Als Impulsgeber, Wegweiser und Beschleuniger digitaler Geschäftsmodelle vertritt der BVDW…

Consultation response

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 5 Aug 2021

SPECTARIS - the German Industry Association for Optics, Photonics, Analytical and Medical Technology welcomes the Commission´s initiative to lay down harmonised rules on Artificial Intelligence. SPECTARIS agrees with the objectives outlined in the European Commission´s proposal (Artificial…

Consultation response

European Telecommunications Standards Institute, 4 Aug 2021

ETSI welcomes the draft Regulation on AI presented by the European Commission (EC) at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0206. The draft Regulation builds on the processes of the New Legislative Framework (NLF) putting harmonised European Standards into the focus of…

Consultation response

eco - Verband der Internetwirtschaft, 2 Aug 2021

About eco: With over 1,100 member companies, eco is the largest Internet industry association in Europe. Since 1995 eco has been instrumental in shaping the Internet, fostering new technologies, forming framework conditions, and representing the interests of members in politics and international…

Consultation response

Small Business Standards, 6 Aug 2021

SBS thanks the European Commission for the opportunity to provide feedback on the proposal for a European Act on Artificial intelligence (the AI ACT). SBS has prepared feedback regarding the impact of the AI ACT on SMEs, especially on technical issues, quality assurance and certification, and…

Consultation response

ResMed, 30 Jul 2021

Please see ResMed's consultation response for the Artificial Intelligence Act attached below. We thank the Commission for the opportunity to provide feedback on the proposed legislation and welcome further engagement on the regulation of AI in Europe.

Consultation response

Fédération des Industries Mécaniques, 22 Jul 2021

One has to acknowledge that the implementation of software techniques and approaches commonly referred to as "Artificial Intelligence" is not a novelty, as self-driving machinery is already placed on the market and put into service especially in the industrial and agricultural sectors. These…

Consultation response

Center for Data Innovation, 6 Aug 2021

The Center for Data Innovation is pleased to respond to the European Commission’s request for feedback on the Artificial Intelligence Act. Please see the enclosed document for our comments.

Consultation response

European Association of Urology, 9 Sept 2020

The European Association of Urology, a membership organisation of more than 18 000 urologists from all over Europe, sees value in the use of Artificial Intelligence (AI) both in terms of the activities of our professional association (e.g and decision support and development of evidence based…

Consultation response

Fujitsu Technology Solutions B.V., 5 Aug 2021

Fujitsu understands the need for European regulation of AI and encourages the European Commission to make all efforts to finalize a framework legislation that can be effective both at European and global level with a strong focus on supporting technology exchange and innovation. In order to do…

Consultation response

Fédération Nationale des Travaux Publics, 5 Aug 2021

L’approche par les risques de la Commission européenne semble être la meilleure approche dans la mesure où elle favorise la confiance dans l’intelligence artificielle sans entraver son développement. En revanche, il est essentiel de garder une marge d’innovation. Une attention particulière doit…

Consultation response

HOMO DIGITALIS ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΕΙΑ, 5 Aug 2021

Παρακαλούμε όπως βρείτε συνημμένη την τοποθέτηση της Homo Digitalis στην ανοιχτή διαβούλευση της Ευρωπαϊκής Επιτροπής για τις διατάξεις του προτεινόμενου κανονισμού για την Τεχνητή Νοημοσύνη. Με εκτίμηση, Η συντακτική ομάδα της Homo Digitalis

Consultation response

European Hospital and Healthcare Federation, 12 Jul 2021

Artificial Intelligence (AI) is a complex phenomenon interfering with the way medical research is conducted, the biomedical data is used, and the healthcare professions and organisations are regulated. AI use in healthcare would then also requires a specific regulatory approach, in addition to a…

Consultation response

Allwyn International AG, 8 Jun 2021

Considering the space limits, we attach our contribution to the "Artificial Intelligence - ethical and legal requirements" consultation Kamil Ziegler Head of Institutional and Government Affairs

Consultation response

Fujitsu Technology Solutions B.V., 10 Sept 2020

Fujitsu is one of the leading global ICT companies and the largest in Japan. Europe is at the heart of our global business. 1 Protecting fundamental rights We support the concept of trustworthy AI, based on European values and protecting Fundamental Rights. Fujitsu aims to incorporate ethics…

Consultation response

Beltug vzw/asbl, 6 Aug 2021

Beltug - VOICE - Cigref - CIO Platform NL - We are the Belgian, Dutch, French and German CIO-associations; the communities of Chief Information Officers (CIO’s) and other senior leaders that are responsible for digital technologies and digital transformations within private or public organisations.…

Consultation response

CIO Platform Nederland, 5 Aug 2021

CIO Platform Nederland welcomes the opportunity to provide feedback on the proposal for the Artificial Intelligence Regulation. We consider the AI proposal a starting point to assess how to honour fundamental rights, health and security, while allowing AI technology to flourish. In brief, an…

Consultation response

Assuralia, beroepsvereniging van verzekeringsondernemingen, 5 Aug 2021

Please find enclosed Assuralia's contribution.

Consultation response

EIT Health, 29 Jul 2021

• EIT Health welcomes the proposed AI Regulation and its ambition to create horizontal legislation overseeing AI and to maximise the safety and trustworthiness of this technology. We welcome the creation of a risk-classification of AI and prohibition of certain AI in alignment with the OECD, as…

Consultation response

DeepMind Technologies Limited, 5 Aug 2021

Please find attached DeepMind's views on the European Commission's proposal on the Artificial Intelligence Act. We thank the Commission for the opportunity to provide feedback and look forward to engaging in further discussions to foster scientific excellence and trustworthy AI in the EU.

Consultation response

Splunk, 5 Aug 2021

The development of artificial intelligence has major potential to improve business processes and services for citizens, but there are a number of complex issues associated with its adoption. Splunk supports a flexible policy framework that builds confidence and trust in AI systems, encourages…

Consultation response

Centre for Information Policy Leadership at Hunton Andrews Kurth LLP, 29 Jul 2021

CIPL welcomes the Consultation on the European Commission’s Proposal for a European Artificial Intelligence Act to feed into the EU legislative process. CIPL is pleased to see that the AI Act incorporates several recommendations made in CIPL’s paper on Adopting a Risk-Based Approach to Regulating…

Consultation response

Amsterdam: AI Technology for People, 10 Sept 2020

The Amsterdam coalition 'AI Technology for People' strongly supports the European Parliament and Council in their efforts to ensure that AI is safe, lawful and in line with EU fundamental rights. The overall goal of stimulating the uptake of trustworthy AI in the EU economy connects closely to the…

Consultation response

European Garden Machinery industry Federation, 9 Sept 2020

EGMF, the European Garden Machinery Federation, would like to provide its feedback in the attachment, on the Commission inception impact assessment regarding a proposal for a legal act on AI requirements.

Consultation response

Fédération Nationale de l'Automobile, 6 Aug 2021

Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Proposal of European Regulation laying down harmonized rules on Artificial Intelligence (AI) to inform citizens and stakeholders about the Commission's work in order to…

Consultation response

EUROSMART, 29 Jul 2021

Eurosmart, the Voice of the Digital Security Industry, welcomes the Commission’s proposal for an Artificial Intelligence (AI) Act. Our association has been advocating for years for EU requirements covering AI systems. Eurosmart would like to comment on the following items -each of them is further…

Consultation response

BlackBerry Limited, 23 Jul 2021

Please find attached our response to the consultation on the draft AI Act. We are thankful to the Commission for giving us the opportunity to contribute.

Consultation response

SICK AG, 22 Jul 2021

The proposed regulation is a welcome initiative but needs significant improvement in some details to be applicable in practice to the cases for which it is intended. SICK AG urgently recommends the deletion of the "Bayesian estimation" from the ANNEX I (Paragraph C). Bayesian techniques are not…

Consultation response

EuroGeographics, 13 Jul 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). We are a passionate advocate for European geospatial data from official trusted sources, in particular when it is harmonised to…

Consultation response

EUnited European Engineering Industries Association, 10 Sept 2020

EUnited is convinced that artificial intelligence (AI) drives and contributes to the digital and green transformation. It can do so across a broad range of sectors from healthcare to manufacturing and beyond, which in turn will lead to badly needed economic growth and the ability to meet numerous…

Consultation response

Data, AI and Robotics (DAIRO) AISBL, 9 Sept 2020

BDVA welcomes the possibility to provide feedback on the Inception Impact Assessment concerning a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence. As already highlighted in BDVA response to the AI Whitepaper, BDVA strongly…

Consultation response

Confederation of Laboratories for Artificial Intelligence Research in Europe AISBL, 6 Aug 2021

CLAIRE welcomes the opportunity to provide feedback and supports the European Commission's drive towards a balance between regulation and innovation, where citizens’ rights are well protected, while facilitating investment and innovation. However, we find that the sum of the initiatives, as they…

Consultation response

Stichting ALLAI Nederland, 6 Aug 2021

See attached file

Consultation response

Trilateral Research, 6 Aug 2021

Trilateral Research is a UK and IE-based ethical technology development and research company. Our experienced interdisciplinary teams apply rigorous, cutting-edge research when developing and assessing new technologies to ensure they achieve sustainable innovation and measurable impact. We believe…

Consultation response

Council of European Dentists, 6 Aug 2021

The Council of European Dentists (CED) welcomes the European Commission’s Proposal for a Regulation on AI to establish a legal framework on AI Systems and believes it to be a step in the right direction in the EU’s effort to categorize AI applications according to risk and acceptability. As in…

Consultation response

Renaissance Numérique, 5 Aug 2021

Please, find attached the contribution of think tank Renaissance Numérique and of the Chair on the Legal and Regulatory Implications of AI of Grenoble Alpes University related to the proposed Artificial Intelligence Act. This contribution focuses on specific dispositions of the text which raise…

Consultation response

Finnish Center for Artificial Intelligence, 4 Aug 2021

The highly commendable goal of the proposed act is to provide a legal framework in Europe that encourages innovation and investments in artificial intelligence, while ensuring that the results are lawful, safe and trustworthy, respecting human rights. In order to reach this goal, the legal…

Consultation response

Asociación Española de la Economía Digital, 3 Aug 2021

Please find attached Adigital´s contribution to the European Commission´s proposal on the Artificial Intelligence Act

Consultation response

Biogen Inc., 2 Aug 2021

We welcome the Commission’s first ever legal framework on AI and its goal to promote Europe’s innovation capacity in AI, which has the potential to speed drug development and improve healthcare outcomes across the continent. We support a risk-based approach to AI with an oversight proportionate to…

Consultation response

Alliance for AI, IoT and Edge Continuum Innovation IVZW, 2 Aug 2021

The Alliance for Internet of Things Innovation (AIOTI) appreciates the use of a Regulation as a legal instrument to help building an EU digital Single Market for trustworthy AI and to avoid regulatory fragmentation. AIOTI welcomes the risk-and New Legislative Framework (NLF) based approach and to…

Consultation response

Gewerkschaft Erziehung und Wissenschaft, 2 Aug 2021

The German Education Union (Gewerkschaft Erziehung und Wissenschaft, GEW) supports the position of the European Trade Union Committee for Education (ETUCE) on the EU Regulation on Artificial Intelligence.

Consultation response

Asociación Nacional de Establecimientos Financieros de Crédito (ASNEF), 30 Jul 2021

ASNEF, the Finance Houses Association of Spain, represented by the Secretary General, Mr. Ignacio Pla Vidal, and duly registered in the Transparency Registry with nº 11218815591-29, submits the following observations: 1. Concerning recital 37, the proposed Regulation mentions the…

Consultation response

Centro Español de Derechos Reprográficos EGDPI, 13 Jul 2021

Estas son las contribuciones del CENTRO ESPAÑOL DE DERECHOS REPROGRÁFICOS EGDPI (CEDRO) a la propuesta de Reglamento COM(2021)206 sobre Inteligencia Artificial (Artificial Intelligence Act). CEDRO es una entidad de gestión de derechos de Propiedad Intelectual establecida en España, autorizada por…

Consultation response

EURALARM, 12 Jul 2021

Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give comments and suggestions on their proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL LAYING DOWN HARMONISED…

Consultation response

Medtech & Pharma Platform Association, 30 Jun 2021

The not-for-profit MPP Association welcomes the European Commission proposal for a Regulation laying down rules on AI. MPP supports efforts to optimize the regulatory framework to create the right conditions for healthcare innovation. We are the opinion that risk categories for AI provide a useful…

Consultation response

Asociación Española de la Economía Digital, 10 Sept 2020

Document attached

Consultation response

Związek Pracodawców Branży Internetowej Interactive Advertising Bureau Polska, 10 Sept 2020

Związek Pracodawców Branży Internetowej IAB Polska przedkłada w załączeniu wkład do konsultacji Komisji Europejskiej dot. Sztucznej Inteligencji.

Consultation response

EURALARM, 10 Sept 2020

Euralarm welcomes the inception impact assessment on Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence. Euralarm shares the view that artificial intelligence (AI) can drive economic growth and improve the security and safety for…

Consultation response

Asociación multisectorial de empresas de la electrónica, las tecnologías de la información y la comunicación de las telecomunicaciones y de los contenidos digitales, 8 Sept 2020

Scope ○ We caution the Commission on considering to significantly expand the scope of the future AI regulation to the open ended category of “automated decision making” This would go against the initial, thoughtful direction proposed in the AI whitepaper that proposes to focus on the risk-based,…