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Alliance for AI, IoT and Edge Continuum Innovation IVZW

AIOTI

AIOTI is a non-profit association promoting innovation in artificial intelligence and the Internet of Things.

Lobbying Activity

AIOTI urges EU to standardize energy data and AI services

22 Oct 2025
Topic — A consultation on the Strategic Roadmap for digitalisation and artificial intelligence in energy.
Message — The group advocates for federated energy data spaces to enable secure data sharing between operators and consumers. They also recommend establishing EU-wide testing facilities and sector-specific guidance for high-risk AI. Finally, they call for mandatory open interfaces to ensure different technologies work across borders.123
Why — Standardization and open data access would help their members scale AI technologies across Europe.45
Impact — Proprietary software vendors may lose market dominance if neutral models become mandatory.67
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

AIOTI welcomes the consultation and generally supports the New Legislative Framework NLF. We believe it is important to preserve its principles as they have served European businesses very well for many years. We are concerned with the suggestion to make DPP a requirement for all products and to use it as a tool for general product compliance. We believe that since DPP is not yet implemented and is related to another EU legislation, Ecodesign for Sustainable Products Regulation (ESPR), it should not become part of the NLF until it becomes implemented and it is clearer how it works in practice. Once it has been demonstrated how DPP operates under ESPR as a sandbox, it can be considered if and how to be included in the NLF.
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Response to Revision of the Standardisation Regulation

18 Jul 2025

Please find enclosed input provided by the Alliance for AI, IoT and Edge Continuum Innovation.
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AIOTI urges clearer ownership rules for EU Data Union

14 Jul 2025
Topic — The consultation seeks to create a coherent legal framework for sharing data.
Message — AIOTI calls for better coordination of open-source efforts to address incomplete documentation. They emphasize the need for technical mechanisms to clarify data ownership and control rights. Finally, they advocate for balancing sector-specific diversity with common standards to enable interoperability.123
Why — Defining technical and legal frameworks would eliminate operational uncertainty for digital businesses.4
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AIOTI calls for balanced telecom consolidation and global security standards

9 Jul 2025
Topic — The EU is consulting on the Digital Networks Act to boost high-speed connectivity.
Message — AIOTI supports telecom consolidation provided European consumers' welfare is duly protected. They demand cybersecurity requirements based on verifiable facts and international standards. The group also recommends harmonized spectrum auction timelines and lower fees to incentivize infrastructure investment.123
Why — Harmonized auction timelines and facts-based security rules provide greater investment and legal certainty.4
Impact — European consumers might bear the burden of costs if market consolidation is unbalanced.5
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AIOTI urges technical focus for EU cybersecurity certification

19 Jun 2025
Topic — This consultation concerns the revision of the European Cybersecurity Act and its certification framework.
Message — AIOTI advocates for certification based on technical standards that allow for measurable and aligned criteria. They propose excluding non-technical requirements from the revised framework because they are not assessable.12
Why — This prevents unpredictable assessments by ensuring requirements are based solely on objective technical standards.3
Impact — Policy makers lose the ability to vet vendors based on non-technical geopolitical risks.4
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AIOTI urges unified standards and flexible regulatory testing

4 Jun 2025
Topic — This consultation gathers feedback on a strategy to boost industrial AI use across Europe.
Message — AIOTI recommends creating unified safety checklists and "Regulated Test Corridors" with reduced data restrictions for trials. They also propose replacing new fundamental rights assessments with existing data protection reports.123
Why — Streamlined compliance and delayed implementation would reduce costs and administrative friction for tech firms.45
Impact — Fundamental rights advocates may lose specific protections if specialized assessments are replaced by general data audits.6
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Response to Technical description of important and critical products with digital elements

14 Apr 2025

Please find enclosed our feedback. We welcome this initiative which is an important step to define the proper implementation of this important EU legislation.
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

The Alliance for AI, IoT and Edge Continuum Innovation IVZW (AIOTI) would like to provide input from our community below. We suggest clarifying when to use the award criteria and/or pre-qualification. We believe it will be advantageous for the award criteria to be applicable (at least) until the European supply chain matures sufficiently to deliver the projects fully and on time. This ensures that existing commitments, including simplification, industrial decarbonisation, the Draghi report, and RED II, are met. We recommend offering reassurance that the Union Custom Code (UCC) will serve as the primary tool for determining dependencies and that all secondary legislation and tools under the UCC will adequately ascertain the origin and manufacturing of a product. We suggest transparency on the calculation of dependencies, both from a methodology perspective (customs data) and a timing perspective (up until the end of 2024 or 2025 or how often this will be calculated). We recommend steering clear of any vague interpretations of environmental and cybersecurity criteria. All forms of evaluations should rely on technical and factual assessments. For instance, the third-party security audits referenced in cybersecurity ought to correspond with the existing cybersecurity framework and remain proportionate and reasonable in scope to prevent imposing excessive cost burdens. Regarding environmental sustainability, we propose clarifying (1) when a criterion can serve as pre-qualification, (2) when it acts as an award, and (3) when it functions as a combination of both. This is crucial because suppliers must be informed well in advance about whether any sustainability factor directly influences R&D, design, and manufacturing times.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

The Alliance for AI, IoT and Edge Continuum Innovation IVZW (AIOTI) would like to provide input from our community below. The current list of relevant technologies and components focuses solely on production and management, neglecting aspects that reduce energy losses. The BMS may assist in optimising energy use according to needs, but it has limited application in minimising energy losses, particularly in heating and cooling. This indirectly impacts the management of energy consumed for these processes. Therefore, we propose to expand the list to include solutions for reducing losses, or create a separate list for these solutions, such as insulation techniques, insulation materials, detection of energy/heat loss (which could be integrated with the BMS), structural designs that reduce the need for heating and cooling, convection mechanisms, and alike.
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Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

25 Jul 2024

The Network and Information Security Directive (NIS2 Directive) strengthens cybersecurity risk-management measures and streamlines incident-reporting obligations for a large number of operators across the EU. From the point of view of the Internet of Things and Edge computing that are among the key technologies of interest for the Alliance for IoT and Edge Computing Innovation (AIOTI), we would like to submit comments to the draft Implementing Act that is subject of this public consultation.
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Response to Interim Evaluation of Digital Europe

1 Jul 2024

Being part of the LeADS project, the Digital Europe Programme has significantly supported initiatives that aim to enhance the demand for advanced digital skills in the context of dynamic technological development and ongoing digital transformation. These initiatives are crucial for ensuring that individuals and organizations can adapt to and thrive in an increasingly digital world, and guide Europe to the goal of adding 20 million new ICT professionals by 2030.
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AIOTI Urges EU Funding for Large-Scale Digital Pilot Projects

28 Jun 2024
Topic — A consultation on scenarios for European connectivity infrastructure and digital market integration.
Message — The group recommends funding large-scale pilots through Horizon Europe to integrate infrastructure and platforms. They also call for standardized network interfaces and a new European partnership for sensor data and IoT communications.12
Why — The organization would secure research funding and reduce technical fragmentation across Europe.34
Impact — Small network providers may struggle to protect existing investments under centralized rules.5
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Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

25 Mar 2024

AIOTI and many other EU organizations are supporting European Green Digital Coalition (EGDC) on doing research and developing the Quantification Methodology specified in ITU-T L.1480 specification, on how to measure the benefits of applying ICT solutions in order to reduce CO2 emissions in other Sectors (e.g., vertical industries), actually ETSI EE and ITU-T SG5 are working, in collaboration also with EGDC, AIOTI and UNFCCC on a new version of standard L.1480 that will be published also as European standard. In this context, the GreenData4All, should recommend as actions for the Green Deal Data Space: 1. Verification and certification of the Quantified Methodology and Assessment, based on ITU-T L.1480, in order to quantify the benefits of applying ICT solutions in order to reduce CO2 emissions in other Sectors. This action will further stimulate ICT and digital innovation stakeholders to collaborate with vertical industry sectors in an efficient way in the context of Green Transitions. 2. Differentiation between B2C and B2B products and services: As a general comment, we would like to stress that it is important that actions for the Green Deal Data Space distinguish between products and services meant to be applied in Business to Consumer (B2C) markets, i.e., consumer products & services, and products & services meant to be applied in the Business to Business (B2B) markets, i.e., industrial products & service. Similar differentiation can be applied to vertical sectors by vertical sector products and on a product group by product group basis. In particular, the requirements for different products & services and their information and documentation are different. It is recommended not to set a one-size-fits-all time-limit, which would be more aligned with existing legislative practices. 3. Ensure a multi-stakeholder and balanced participation of stakeholders, including manufacturers, integrators, operators, standardization bodies and member states representatives to be involved with the actions for the Green Deal Data Space in order to realize and foster the Green Transition.
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act

AIOTI urges EU to exclude chips from Cyber Resilience Act

23 Jan 2023
Topic — A proposal setting mandatory cybersecurity requirements for hardware and software digital products.
Message — The organization recommends excluding individual components like chips and microprocessors from the regulation to focus solely on finished devices. They argue that component suppliers often do not know the end use of their products. Furthermore, they propose extending the incident reporting timeline from 24 hours to 72 hours.123
Why — This would shield component and software suppliers from legal liability and complex compliance costs.4
Impact — Original equipment manufacturers would bear the entire burden of security certification and liability.5
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Response to Sustainable Products Initiative

21 Jun 2022

The European Commission published on 31 March 2022 a proposal for a Regulation on Ecodesign for Sustainable Products (the Regulation). The proposal addresses product design, which determines up to 80% of a product's lifecycle environmental impact. It sets new requirements to make products more durable, reliable, reusable, upgradable, reparable, easier to maintain, refurbish and recycle, and energy and resource efficient. In addition, product-specific information requirements will ensure consumers know the environmental impacts of their purchases. All regulated products will have Digital Product Passports (DPP). The Alliance for Internet of Things Innovation (AIOTI) welcomes the initiative and wishes to provide additional comments from the European IoT and Edge Computing ecosystem perspective, which are enclosed.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

AIOTI welcomes the European Commission’s efforts to address the critical need to improve the energy performance of Europe’s building stock. With a contribution of 36% to the EU CO2 emissions from building operations, mainly from the generation of energy, it is evident that decarbonization of energy generation is of highest priority and reducing unnecessary energy consumption a quick first win. The unleash of a renovation wave for that matter, is a challenge AIOTI fully embraces. It is with this perception that we have viewed the proposed recast of the EPBD and how it contributes to the ‘Fit for 55’ targets. AIOTI raises the following concerns and proposes recommendations: • The recast should accelerate the decarbonization of buildings, while contributing to the realization of liveable and affordable conditions for all. It should incentivize the transition from a ‘sustainability business case’ to a ‘sustainability case of living’. • The recast should better support switching to zero-emission, low-carbon solutions such as electricity-based appliances (e.g. heat-pumps) and smart solutions (e.g. blockchain identifying time-window for lowest electricity cost), as to maximise local energy generation and consumption, while minimizing impact on the public energy distribution grid. AIOTI’s feedback is tailored towards a future-looking recast based on: • Approaching buildings as an infrastructure supporting society to live fulfilling lives, through providing healthy, safe and sustainable regenerative conditions. • Decarbonisation of built environment through energy efficiency and flexibility at scale • Reducing explicit carbon emission targets create a clear reference of communicable and measurable impact reduction • Recognition of the importance of smart IoT solutions for measuring actual impact and performance like energy efficiency and healthy living conditions over time. • Support of switching to decentralized zero-emission low-carbon energy solutions • Prioritize projects that minimize impact on the public energy distribution grid, as to stimulate local energy generation and consumption • Acknowledgement of the public energy distribution grid for security and quality of supply • Facilitated deployment of smart technologies which empower consumers to manage their health, comfort, budget and environmental impact and increase efficiency of the local energy system • A robust framework for data ownership, exchange and interoperability supporting the integration of RED and services
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Response to 2022 Strategic Foresight Report

17 Mar 2022

Green and digital transformation requires a combination of innovative mindset, technology and infrastructure, skilled people, open markets and leadership. In particular, we would like to emphasize that ICT will play a central role in addressing the climate and environment challenges EU faces, both by deployment of ICT technology to support other industrial sectors to reduce their emissions and environmental footprint (ICT for Green), as well as by addressing the ICT sector’s own climate and environmental footprint through Green ICT programmes. In the context of AIOTI, we highlight the two key ICT technologies: IoT and Edge Computing. Digital transformation of business generates significant efficiency gains including energy savings Despite disappointing productivity growth in most OECD countries during the 2010s, new technologies like IoT, edge computing, cloud computing, 5G, AI resemble previous general purpose technologies in their potential pervasive impact to boost productivity in almost all economic sectors. There is also growing real-world evidence that the productivity impacts of the fourth industrial revolution could be profound. Digital transformation does not just benefit larger companies, but as well SMEs. Introducing smart contracts and automating back office functions for example, can reduce late payments and improve business cash flow. Going online and trading across borders can enable SMEs to reach a similar number of customers as larger rivals. Finding new ways to work can also reduce costs, by moving to a shared office provider for when working from home is not desired. Larger firms may keep large offices for prestige, marketing and other advantages. SMEs who are adopting digital tools increased their productivity by 16% on average. 45% of SMEs saw an increase in sales after they started to accept digital payments (avg. increase of 12%). Digital payments can be processed x7 faster than non-digital payments, saving time for owners/employees. Green transformation reduces GHGs Moreover, it is important to be emphasized that ICT, e.g., IoT and edge computing, will play a central role in addressing the climate and environment challenges EU faces, both by deployment of ICT technology to support other industrial sectors to reduce their emissions and environmental footprint (ICT for Green), as well as by addressing the ICT sector’s own climate and environmental footprint through Green ICT programmes. Figure 1 lists examples of the types of scenarios in delivering ICT for Green and Green ICT objectives. Moreover, Figure 1 shows that in the ICT for Green scenarios, the usefulness of ICT can reduce the GHG (or carbon footprint in industrial domains) on industrial sectors that is 7 to 10 times of the ICT carbon footprint. In a variety of vertical industry sectors, companies tend to use absolute metrics to assess their progress on decarbonization. Absolute emission reduction goals are also favored by environmentalists to measure the overall carbon impact a company has on the environment. This approach may work for many of the verticals whose business volume only vary moderately; However, for the overall ICT industry, absolute carbon emission may not be the best metric to assess its progress on de-carbonization, as the usage of mobile networks, fixed networks, and data centers has expanded rapidly around the world in the past decade as society has become more digitalized. As such, de-carbonization efforts in the ICT industry may not be fully satisfactory if they are targeting absolute reduction. Instead, it might be useful for ICT infrastructure operators to focus at their de-carbonization progress relative to the amount of data they process. To create a link between carbon emissions and data traffic, the relationship between carbon emission and primary and secondary energy consumption needs to be understood.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The RED builds on the European Green Deal, in which the Commission set out “a new growth strategy that aims to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use. It also aims to protect, conserve and enhance the EU's natural capital, and protect the health and well-being of citizens from environment-related risks and impacts”. • AIOTI strongly supports this strategy • AIOTI strongly supports the reduction of GHG emissions of at least 55% by 2030 compared to 1990 as a concrete element of this strategy • AIOITI believes that an earlier date then 2050 needs to be set for the European Union to achieve carbon neutrality, given the current climate facts (e.g. IPPC report August 2021) and lack of clear 1,5C measures agreement in the recent COP26 (November 2021). • AIOTI strongly supports the strategy to transition fossil based energy sources to renewable sources. To this purpose AIOTI strongly recommends a higher target than 40% by 2030 for the simple reason given in the previous point. The weighing of this target to ‘prevent overshooting the climate target’ and thus limiting to 40% is very debatable given the climate developments and the charter for fundamental right. With a country like Sweden already at 60% renewable energy, this would be a good target for the EU by 2030. Energy generation is responsible for 75% of the GHG emission, and we strongly recommend using the transition to renewable sources as a key driver for a full societal transition towards circular and renewable concepts. We believe the technical solutions are mainstream. To this matter AIOTI recommends to amend the directive recast to include more explicitly the development of local renewable energy generation since the current directive is foremost focusing explicitly on current energy infrastructures. In addition AIOTI perceives the current break down of existing energy applications as a missed opportunity redesigning the European energy landscape accelerating the transition towards a circular, net-zero carbon Economy and Society, which is the Commission’s ambition.   AIOTI would like to emphasize the need for integral approaches to the Green Deal ambition, meaning designing back from the future ambition. Rather than trying to enforce an optimization from our current implemented solutions. Based on for example the IPCC report of August 2021, it is clear we need giant leaps in transforming our society and economy, instead of small optimization steps. In particular, IoT and Edge Computing are two elements in a larger family of technologies to deliver effective and sustainable systems. Currently many enabling technologies, like IoT, edge computing, smart connectivity, AR/VR, AI/ML and distributed ledger technologies are being deployed and used in many facets of the economy and vertical industry domains. The use of those enabling technologies can support sustainable solutions that will be able to achieve the objectives of the European Green Deal and the large-scale implementation of Renewable Energy. Those technologies, such as IoT, edge computing and smart connectivity can function as enablers of such solutions and at the same time their use will enable energy networks and consumers to become more energy efficient in general, thereby reducing energy consumption at a time when the future of our environment depends on it. These enabling technologies are supported by an evolved ICT infrastructure addressing the connectivity and computing horizontal features.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

The EED builds on the European Green Deal, in which the Commission set out “a new growth strategy that aims to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use. It also aims to protect, conserve and enhance the EU's natural capital, and protect the health and well-being of citizens from environment-related risks and impacts. • AIOTI strongly supports this strategy • AIOTI strongly supports the reduction of GHG emissions of at least 55% by 2030 compared to 1990 as a concrete element of this strategy • AIOITI believes that an earlier date then 2050 needs to be set for the European Union to achieve carbon neutrality, given the current climate facts (e.g. IPPC report August 2021) and lack of clear 1,5C measures agreement in the recent COP26 (nov 2021). • AIOTI strongly supports prioritisation of the principle to increase energy efficiency, meaning a realizing of a certain output with minimum energy consumption. • To this matter AIOTI perceives the proposed EED recast as an attempt to try to impact detailed energy consumption equipment, while not seeing the bigger integral impact. AIOTI fears that the current EED approach will only create a gradual and laborious increase of energy efficiency. • AIOTI misses the clear implication of the Green Deal ambition in the EED, as is now proposed in (50) ‘Not promote activities that are not environmentally sustainable such as use of solid fossil fuels’. In our view it would be logical to state the ban of solid, liquid or gaseous fossil fuels for energy generation in favour of no-emission, renewable solutions. We believe that sufficient alternatives are available, it will strengthen the position of the EU, by strongly reducing dependency from fuel imports to EU, as well as generating the co-benefits of introducing renewable energy sources to health, air quality, GHG emission reduction and more. Technical solutions from the wide IoT field are already available to ensure optimal use at scale.   AIOTI would like to emphasize the need for integral approaches to the Green Deal ambition, meaning designing back from the future ambition. Rather than trying to enforce an optimization from our current implemented solutions. Based on for example the IPCC report of August 2021, it is clear we need giant leaps in transforming our society and economy, instead of small optimization steps. In particular, IoT and Edge Computing are two elements in a larger family of technologies to deliver effective and sustainable systems. Currently many enabling technologies, like IoT, edge computing, smart connectivity, AR/VR, AI/ML and distributed ledger technologies are being deployed and used in many facets of the economy and vertical industry domains. The use of those enabling technologies can support sustainable solutions that will be able to achieve the objectives of the European Green Deal and Energy Efficiency. Those technologies, such as IoT, edge computing and smart connectivity can function as enablers of such solutions and at the same time their use will enable energy networks and consumers to become more energy efficient in general, thereby reducing energy consumption at a time when the future of our environment depends on it. These enabling technologies are supported by an evolved ICT infrastructure addressing the connectivity and computing horizontal features.
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Response to Standardisation Strategy

3 Aug 2021

The Alliance for Internet of Things Innovation (AIOTI) would like to submit its response to the public consultation on the EU standardisation strategy roadmap. Please find enclosed our response.
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Response to Requirements for Artificial Intelligence

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 introduce specific rules for specific uses, rather than legislating the technology as such. We recommend that this framework is maintained during the legislative work on the file. AIOTI supports that the proposal seeks to create obligations for all entities involved in the design, development, and deployment of AI. However, given that extensive exchanges between stakeholders across the AI value-chain will be necessary for the purposes of appropriate compliance and enforcement mechanisms, we stress that the corresponding obligations should be placed on the entities best placed to respond to them. We welcome that the Proposal allows for self-assessment in most cases, which benefits the development of industrial AI, a strategically important sector in Europe. We also support the use of the principles of the NLF which has proven to be a technological-neutral way of regulation. More we say in our enclosed contribution.
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Response to Revision of the NIS Directive

11 Mar 2021

On behalf of the Alliance for Internet of Things Innovation, please find enclosed our feedback to the draft proposal of the revised Network and Information Security Directive.
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Response to Legislative framework for the governance of common European data spaces

29 Jan 2021

Overall: For most IoT ecosystems, in order to support addressing societal challenges having trusted open and dynamic data readily available as core facility, it is a prerequisite to have such data and derived data and being able to use it, to add to such ecosystems and understand how to share and otherwise being able to use such data and derived data. AIOTI, therefore, supports the EU Data Strategy for having a more comprehensive approach to data sharing, data governance, ownership, access and data spaces. AIOTI also supports the Data Governance Act's main objectives of open data sharing, improved data sharing and data altruism, common EU data spaces, ensuring legal certainty which will drive sharing and availability of data, as well as communicating best practice in data sharing. Main principles: A major objective should be that end users can trust the data they have access to, and that the data has accompanying metadata concerning its sources thereby providing information about its provenance. Data sharing should rely on interoperability and other standards (taking into account the (implementation of) the European Interoperability Framework and also international ones) and portability to avoid any vendor lock-in. Data flows in B2B domain should be based on contractual freedom in data sharing. Data and data spaces are very relevant to make IoT ecosystems work. AIOTI already provided a separate set of comments about Common European Data Spaces. IPR, commercial confidentiality and legitimate business interests needs to be properly protected from unlawful access. Access to data for researchers is important and needs to be open, while objectives of use must be clearly expressed. Controlled access to data should be based on clear cybersecurity requirements. The role of the public sector should be to provide a role model in providing access to data, as well as to guaranteeing access to data. Potential anti-competitive behaviours by open data users (including users that derive data from such open data sets and data sources) that will be tackled with the Digital Services/Market Act should be carefully balanced with incentives from the European Data strategy and Data Governance Act. The process of requesting the re-use of public sector data introduced by the mechanism under the Regulation must be simple, time-efficient, and not require companies to do time-consuming investigate work, especially for SMEs. This mechanism should not become a bottleneck for companies to request such data under the Regulation. Potential obstacles: Protection of privacy: can still be a big hurdle, more guidance and perhaps regulation on how to anonymise data is needed from the European Data Protection Board (EDPB) as well as more use of industry standards, in particular for mixed data sets. Furthermore, except for the current interim period regarding the UK, it is not yet clear how data transfers with the UK and US will continue and how adequacy will be achieved. National bodies will decide whether to grant or refuse access to sensitive public sector data There are concerns that this may lead to divergent approaches across the EC with resultant fragmentation of the EU common data space. Secure interoperability is not standardized for existing interfaces used by IoT devices which Is a pre-requisite for data governance. More on specific provisions could be found in the enclosed document.
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Response to Review of the general product safety directive

30 Jul 2020

Alliance for Internet of Things Innovation (AIOTI) is the multi-stakeholder platform for stimulating IoT Innovation in Europe, bringing together small and large companies, start-ups and scale-ups, academia, policymakers, and end-users and representatives of society in an end-to-end approach. GPSD is technology-neutral and safety provisions are fit-for-purpose in the context of new and emerging technologies. Explicitly mentioning and/or introducing provisions that are technology-specific (AI, robotics, IoT) have no added value and would help to push the uptake of innovation due to legal uncertainty. If the decision is to review GPSD, we believe the best option is to transform directive into the EU Regulation. Definitions would have to be, such as "products" and "high-risk" within a context-based approach. In any review, it is essential to keep full coherence with the New Legislative Framework to avoid overlaps and duplications with any upcoming legislative reviews and avoid a patchwork of requirements for placing products on the single market within various instruments (regulations, directive).
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Response to Legislative framework for the governance of common European data spaces

30 Jul 2020

Alliance for Internet of Things Innovation (AIOTI) believes the future of the Single Digital Market is underpinned by IoT data. In the future Internet navigation-related data will represent a minor portion of all datasets. Most of future data will be generated by IoT devices and sensors. It is therefore essential to build a strategic vision of how IoT data will be generated, searched, accessed, shared and exchanged, in accordance with the European values and to set up relevant technical standards.AIOTI supports the four general principles provided in the inception Impact Assessment. AIOTI provides comments with relation to the future of IoT data. More comments are given in enclosed document.
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Response to Establishment of a smart readiness indicator for buildings

16 Jul 2020

AIOTI Working Group 13 Smart Buildings and Architecture welcomes the voluntary Smart Readiness Indicator (SRI) under the Energy Performance of Buildings Directive. If implemented in a balanced, consistent, and holistic manner, the SRI has the ability to raise awareness about the benefits of smart technologies and drive the uptake of new technologies in the building sector. To ensure a balanced, consistent, and holistic approach to the SRI framework, We would like to draw you attention to our AIOTI Working Group 13’s position paper on the SRI as supplementary to our response. The paper can be found here: https://aioti.eu/wp-content/uploads/2019/09/AIOTI-SRI-Position-Paper-Final-for-Publication.pdf . To ensure a balanced, consistent, and holistic approach to the SRI framework, this paper outlines AIOTI Smart Building and Architecture Working Group's position on the main questions guiding the 2nd phase of the SRI study. Among other recommendations, AIOTI urges the Commission to consider: While the development of this catalogue of smart ready services has been developed with substantial stakeholder feedback, it misses a key criterion: network readiness. The SRI Impact Assessment highlights the importance of ‘broadband access’ in order for smart systems to function smoothly. However, the current catalogue does not include network readiness as a domain, rather considers it a secondary piece of information, which would not affect the SRI, score of a building. With advances in built world technology showing no signs of slowing, the smart technology requirements are rapidly becoming more complex. By including network readiness as another domain in the service catalogue, it would provide users with transparency and enable the objective benchmarking of how well designed and connected different buildings are in the market. Connectivity is essential for the successful deployment of all smart technologies in buildings. The possible services with functionality levels in the network readiness domain have been outlined in AIOTI position paper. The review clauses in the Delegated Acts should include a mid-term review in 2023. A mid-term review of the Delegated Regulation on the calculation methodology, would be particularly welcome to assess the validity of the initial weightings for the criteria and to consider the inclusion of additional criteria. Ensure the SRI Is compatible with the LEVEL(S) scheme, Energy Performance Certificates, and the Broadband Cost Reduction Directive. Ensure the SRI framework is adaptable and accounts for the differences in building contexts, typologies and geographic locations through distinct frameworks for building types.However, data from the SRI must be consistent and comparable between Member States’ SRI schemes in order that it can be leveraged effectively to support the development of policies across the EU to drive the uptake of smart technologies in the built environment. AIOTI stresses the need to avoid fragmented approaches by Member States wherever possible. For the widest use and adoption of the SRI, the framework must be flexible in assessment by ensuring the format and presentation of information is conveyed in a meaningful manner so it is easily understood.
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Response to Farm to Fork Strategy

16 Mar 2020

Alliance of Internet of Things Innovation (AIOTI) Working Group 06 (Smart Farming and Food Security) is the key meeting point of EU-based stakeholders interested in developing and exploiting the benefits of IoT (technologies, ecosystem and infrastructure) in the domains of farming for food production and food safety, from farm to fork. The scope of the working group encompasses precision farming (IoT devices, data management tools and issues) applied to multiple farming modalities, food traceability and safety throughout the whole food chain, considering the business, policy and societal dimensions. Overall, AIOTI WG06 is supportive of the proposed roadmap. WG06 believes Internet of Things (IoT) technologies have the potential to deliver impact across food value chains by reducing costs, helping farmers and all stakeholders to make sustainable decisions, improving access to information and markets, and empowering youth in particular. IoT enables the collection of real time data like weather, temperature, moisture, prices or GPS signals, opening the door to the application of intelligent data analytics that can provide farmers insights on how to optimise and increase yield, improve farm planning and make decisions about resources. But IoT is not only for the farms. IoT is the enabler of a whole data-driven, safe, farm to fork food chain, interconnecting food systems in support of a circular economy for food. Therefore we encourage to place IoT and digital tools at the core of European and national farm to fork growth strategies and policies.
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Response to European Partnership for Smart Networks and Services

27 Aug 2019

AIOTI has reviewed the inception impact assessment of European Partnership for Smart Networks and Services document and has summarized its comments in this document that is submitted as a response to the public consultation. AIOTI has presented its views on the Horizon Europe program already in August 2018, which were shared with the European Commission and national public authorities. Following the co-design process that is preparing the first Strategic Plan for Horizon Europe – the European Union Framework Programme for Research and Innovation 2021 – 2027 (Horizon Europe), AIOTI developed in collaboration with many stakeholders and industrial associations a list of critical innovation activities supporting a new European partnership in Horizon Europe that would go to more ambitious innovation and improve on future partnerships under Horizon 2020. The strong rationale for this is that Europe must orchestrate its scarce resources in new research and innovation in such a way that they collaborate across modalities and the value chain to deliver not only research results but also socio-economic results and address the new challenges that are brought by the convergence of technologies such as 5G, Internet of Things/Industrial Internet of Things (IoT/IIoT), edge computing and Artificial Intelligence (AI) including at the edge. Namely, the existing partnership in Horizon 2020 on 5G technologies delivers an infrastructure for Europe. However, the new partnership in the Horizon Europe program should go beyond infrastructure deployment to include end-to-end industrial applications and related services that contribute to socio-economic development and financial justification of costly infrastructure. Those are strongly related to IoT/IIoT, sovereign data marketplaces, edge computing, AI including at the edge and cloud computing. These topics are not covered at all in the inception impact assessment document. The document is focused almost exclusively on 5G and "beyond 5G" infrastructure. In some aspects, it can be seen as a clear step back over previous statements and signals given by the EC to the industry on a new broader European Partnership addressing "Intelligent connectivity, IoT/IIoT, smart networks, applications and services" that brings together 5G, IoT/IIoT, edge computing, AI including at the edge, technologies that through their convergence are fuelling the Fifth Wave of Computing. The following reference from the inception impact assessment document is only partially touching upon broader scope: …(the partnership) would also build on the results achieved by coordinated actions in the field of networks and services carried out under Horizon 2020, such as the 'industrial alliance for Internet of Things innovation' and the Cloud Stakeholder Group.   While staying true to its long-standing commitment to openness, competition, and free and fair trade, the EU must also acknowledge and better understand the new dependencies and vulnerabilities that accompany technological progress, ubiquitous connectivity and address the new convergence of technologies through a new strong European Partnership addressing "Intelligent connectivity, IoT/IIoT, smart networks, applications and services" that builds on the results achieved by coordinated actions in the field. Working with 5G IA, AIOTI has developed a vision document laying the foundation for how infrastructure and application innovations should go hand in hand and how this can be included in common topics for research and innovation in the areas of intelligent connectivity, IoT/IIoT and applications. More details are given in the enclosed document.
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