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Fujitsu Technology Solutions B.V.

FUJITSU

Fujitsu is a leading provider of IT-based business solutions for the global market.

Lobbying Activity

Meeting with Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and Japan Business Council in Europe and

11 Dec 2025 · Discussion on EU-Japan trade, competitiveness, and industrial policy.

Response to EU quantum Act

9 Dec 2025

Thank you for the opportunity to contribute to this call for evidence. At Fujitsu, we are convinced that the EU can secure technological sovereignty in quantum only by preserving industrial competitiveness through an open, interoperable ecosystem that cooperates with trusted partners like Japan. A flexible, strategically aligned Buy European Quantum approach is essential to avoid limiting innovation, market growth, and joint research. This should come together with a strong cooperative approach with like-minded Countries resulting in co-investments in R&D, co-development of both software, hardware and Quantum applications. Clear EU guidance should ensure that co-development, co-investment, and cross-border R&D with Japan remain eligible, especially for application-driven quantum projects. Europe should simultaneously advance quantum applications and hardwaresoftware co-design, supported by shared testbeds and sandbox environments that accelerate learning and adoption. Sustained, structured cooperation with Japan strengthensnot weakensEU resilience and leadership and should be formalized through trusted mechanisms for sharing IP, code and critical information. More details are provided in the attached document.
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Meeting with Bernard Guetta (Member of the European Parliament) and BlackRock and

4 Jun 2025 · Discussion with global investors on the future of Europe

Response to Quantum Strategy of the EU

3 Jun 2025

The upcoming EU Quantum Strategy must take a coordinated approach across the supply chain from basic research to commercial deployment supporting the full technology stack. To stay ahead, Europe must invest at scale, close the talent gap, fast-track standards, and build a truly frictionless Single Market for quantum ventures of all sizes. Also, strong and like-minded countries are needed to positively impact the competitiveness and economies of the EU and its partners. It is key for the EU to have clear goals of achieving quantum computing (QC) capabilities by investing on research and most importantly deployment of Quantum technologies and applications. This should be done by investing on: - Integration of AI, HPC, and QC capabilities, - Support to the EuroHPC - Use of innovative procurement procedure promoting strategic cooperation with like minded Countries such as Japan and based on ongoing Digital Partnerships to leverage synergies - Through the EU Quantum Act focus on advancing of quantum chip production in cooperation with trusted Countries such as Japan. The European Commission should strengthen strategic cooperation on quantum technologies with like-minded Countries such as Japan under the EU-Japan Digital Partnership. By adopting innovative public procurement frameworks, the EU can unlock co-investment opportunities, align with global standards, and ensure interoperability of emerging quantum ecosystems. This collaboration would accelerate commercial deployment and research outcomes, enhance digital sovereignty, and secure a leadership role for both partners in the global quantum race. The EU has committed over 1 billion to the Quantum Flagship initiative (20182028). Japans Moonshot R&D Program allocates over ¥100 billion (650 million) for quantum and post-quantum technology development through 2030. Despite these investments, quantum development remains fragmented. Coordinated procurement and R&D could mitigate duplicated efforts, align technological standards, and foster trusted supply chains. Joint procurement can leverage up co-investments. Coordinated projects reduce redundancy, improving capital efficiency by 2030%. It can encourage as well private investment by de-risking innovation cycles and increasing technology readiness levels (TRLs). Stronger Cooperation with like-minded Countries can Position the EU and its strategic partners as co-leaders in setting quantum safety, security, and performance standardscounterbalancing initiatives led by other Countries. This can enhance regulatory alignment in future WTO Tech Standards discussions and Interoperability/Supply Chain Security as instance on Post-Quantum Cryptography (PQC). Finally, this can reduce reliance on third-country technologies by creating a trusted transnational value chain.
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Response to Apply AI Strategy

3 Jun 2025

What should be prioritized to support AI uptake in your area? - Data and Security: more support with regulations and compliance processes in relation to cybersecurity for AI and use/development of AI tools for cybersecurity. - Net Zero (Digital Twins): more support with regulations and compliance processes in relation to digital twins research, in particular for use of behavioural data. Are there specific examples, needs, or barriers? - Data and Security: more transparency is needed in relation to incident responses and information regarding cybersecurity breaches and compromises. - Net Zero (Digital Twins): limited access to behavioural data, in particular for non-academic research centres. Anything else that should be taken into account? - Data and Security: currently there is a strong open source approach to cybersecurity tools and datasets, which positively impacts research. - Data interoperability (i.e. interoperability of data governance frameworks in EU and other countries) is a key barrier. To support sustainable AI adoption and global competitiveness, the EU should strengthen strategic cooperation with like-minded partners such as Japan. Joint EU-Japan initiatives for instance on interoperable standards, trusted data spaces, and AI R&D could accelerate innovation while reinforcing democratic values. Targeted public-private funding schemes and coordinated tax incentives for AI development, particularly benefiting SMEs and scale-ups, would further deepen this partnership. The EU could also promote regulatory alignment and experimentation through cross-border sandboxes with Japan, fostering trust and legal certainty under the AI Act. Enhancing talent mobility via fast-track visas and mutual recognition of digital skills and co-investing in shared computer infrastructure would support innovation ecosystems on both sides, while reinforcing resilience across the AI value chain. AI tools are increasingly used in cybersecurity, anomaly detection, and customer service. These tools reduce routine administrative and data-intensive tasks, allowing human resources to focus on higher-value decision-making, client interactions, and strategic development. AI has also created new cross-functional roles, especially in areas such as AI ethics, regulation, and project deployment in the EU.
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Response to Technical description of important and critical products with digital elements

18 Apr 2025

We appreciate the opportunity to contribute to the consultation on the draft implementing regulation under Article 24(9) of the Cyber Resilience Act (CRA). Fujitsu, as a global Japanese company with a significant presence in Europe and deep expertise in B2B services, cloud and on-premise infrastructure, IoT, and cutting-edge fields such as quantum computing and artificial intelligence, we fully support the objectives of the CRA in enhancing cybersecurity resilience across the EU. At the same time, we wish to raise several concerns and recommendations to ensure the regulation remains proportionate, technically robust, and globally coherent. First and foremost, we welcome the effort to define the concept of severely exploitable vulnerabilities as it is vital for establishing a clear and workable reporting framework. However, the current criteria appear overly broad and may lead to an excessive number of non-actionable reports. This could dilute the effectiveness of the reporting system, creating noise and increasing the burden both for national authorities and economic operators, without delivering commensurate security benefits. In our view, the technical criteria should be more closely aligned with well-established global standards, which are already used extensively by industry. We also suggest integrating a stronger emphasis on whether a vulnerability is actively exploited in the wild. This would bring the regulation closer to real-world cybersecurity risk management and ensure that limited resources are directed where they are most needed. Given our role as a system integrator and solution provider operating in highly complex B2B chains, we also wish to highlight the need for clearer guidance on how responsibility for vulnerability management is distributed across the supply chain. In practice, many products with digital elements are composed of a multitude of third-party components, including open-source software and hardware developed across jurisdictions. It is not always feasible for a manufacturer to have full visibility over these elements or control over their security patching cycle. It is also common for vulnerabilities to be disclosed initially by upstream developers or coordinated through sector-specific Computer Emergency Response Teams (CERTs). The regulation should reflect this reality by supporting shared responsibility models and explicitly recognizing the role of coordinated vulnerability disclosure (CVD) frameworks, such as those outlined in ISO/IEC 29147 and ISO/IEC 30111. Doing so would ensure that accountability is realistically distributed and that the regulation supports, rather than disrupts, mature global practices. Furthermore, we strongly believe that the CRAs implementation must be harmonized with international cybersecurity ecosystems. As a Japanese company, we are already subject to national obligations and active participants in several international security collaborations. Many companies with global operations engage with multiple CERTs and follow structured international processes for vulnerability management. The implementing regulation should therefore allow for cooperation with home-country or sectoral CERTs alongside ENISA, and avoid imposing duplicative requirements where equivalent safeguards and disclosure procedures already exist. Language allowing mutual recognition or interoperability of existing global disclosure regimes would encourage stronger engagement with EU rules, rather than risk companies maintaining parallel compliance systems. Particular attention should also be paid to the unique context of high-innovation technologies. Areas such as AI, quantum computing, and industrial automation operate within fast-evolving threat landscapes and development cycles. For such technologies, a rigid, uniform approach to vulnerability classification or reporting timelines may be counterproductive and risk stifling innovation. We encourage the Commission to take
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology) and

10 Mar 2025 · Fujitsu’s presentation on developments in their business activities

Meeting with Christel Schaldemose (Member of the European Parliament, Delegation chair)

17 May 2023 · AI technology and AI ethics

Response to Requirements for Artificial Intelligence

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 that, this regulation must be as simple as possible with clear definitions and limit the obligations for all stakeholders in the value chain by focusing on essential rules and requirements. We appreciate the efforts of the European Commission in providing the first horizontal-framework proposal for a regulation of such a complex topic with impact on many technologies and ecosystems-value chains with clear synergies with other regulations at European level. Artificial Intelligence (AI) must be seen primarily as a great opportunity to improve our society and the life of all citizens rather than a threat. It is important to make sure that this technology does not cause harm to anyone and in particular to the most disadvantaged categories of citizens, ensuring a responsible rollout of the technology with particular focus on privacy, cybersecurity and transparency. Fujitsu is promoting a Human-Centered development of AI solutions in full respect of human rights, ethics values and in line with the UN SDGs. In 2018 Fujitsu formulated the "Fujitsu Group AI Commitment," demonstrating dedication to Safe and Secure Use of AI. In this statement, we highlighted five main principles: 1 - Provide value to customers and society with AI 2 - Strive for Human Centric AI 3 - Strive for a sustainable society with AI 4 - Strive for AI that respects and supports people's decision making 5 - As corporate social responsibility, emphasize transparency and accountability for AI Strong emphasis must be placed not only on respecting fundamental human rights but also on sustainability, climate change and green transition in line with the UN SDGs, the recent conclusions of the G20 and the European Commission strategies. Fujitsu strongly believes in the importance of having a global approach toward AI. An open dialogue about this hugely important technology, allocating strong efforts on Global Standards, R&D investments, shared definitions, rules and principles, will encourage strong cooperation and trade among countries sharing the same principles and fast adoption of AI systems that goes across borders. Attached a more detailed response to this consultation that incorporates feedbacks and suggestions from Fujitsu experts coming from Europe, Japan, US, Canada and other Countries.
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Jul 2021

Fujitsu acknowledges the efforts to critically review the legal frameworks that apply to innovative technologies such as AI. It is of high importance that both for developers, manufacturers and providers of such new technologies, as well as for the users or persons otherwise affected by these technologies, legal frameworks exist that take into account the interests of all stakeholders in a balanced and appropriate manner. However, it is also important that this review is based on verified facts and experience. Any necessary adaptation of the legal framework should accompany and support technical development in a timely manner but should not be ahead of it. Otherwise, further innovations could be hindered by inappropriate and impractical legal requirements. While great progress has already been made in the development of products and services that use AI, the use and dissemination of such products and services in practice has only just begun in many areas. The use of AI in further application scenarios and increasing empirical data will support a well-founded assessment of any risks and the actual need for legal adaptation. Against this background, it seems advisable to be cautious about adapting the existing legal framework in this phase and limiting the necessary flexibility for future developments in particular considering the ongoing discussion around the so-called “AI Act”. Basically, the allocation of responsibility and risks made by the existing legal framework should also be maintained for products using AI. It is not evident why something different should apply to products using artificial intelligence than to products without using this technology. Definition of “product”: Extending the strict product liability based on the Product Liability Directive 85/374/EEC (the Directive) to intangible products (e.g. digital content/software) as such ("stand-alone") does not seem necessary, as such intangible products can only cause physical/material damage to a person or physical object in combination with a tangible product. Product liability for intangible products should also not be extended to defects resulting from interaction with other products and services (e.g. IoT). This is because the producer of digital content or software can hardly foresee or control which other intangible products the user will combine with this digital content or software. Range of damages: Extending the range of damages for which compensation can be claimed based on the Directive to include non-material damages (e.g. loss of data or privacy infringements) would not correspond to the original purpose of the Directive. The original goal is providing consumers with compensation, even without a contract and regardless of fault, under low prerequisites if they have been harmed by a defective product. This low prerequisites for a claim are balanced by the fact that the claim must refer to injury to the person or damage to an object for private use, i.e. damage to high legal interests. This balance would be affected by an extension to immaterial damage. Burden of proof: The necessary proof that a product is defective can be difficult for an injured party to provide, especially in the case of complex products. However, also in this respect it is not evident why something different should apply to products that use AI than to products that do not use AI. A reversal of the burden of proof does not appear necessary to protect the interests of the injured party. The case law on existing product liability law has already confirmed that the injured party is entitled to relief in the burden of proof (e.g. prima facie evidence, presumption of defect). Thus, a product defect is regularly already assumed if a product has led to personal injury or property damage despite proper use. If the product does not comply with the relevant technical standards or statutory safety regulations, this also gives rise to a rebuttable presumption of defectiveness.
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Response to Requirements for Artificial Intelligence

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 in the AI system lifecycle for all ‘high-risk’ AI solutions, consistent with guidance from the EU. We recommend the European Institutions to create "An Ecosystem of Trust" where AI and Ethics can have a key guiding role in the development of new solutions (as set out in the Fujitsu Group AI Commitment ). Fujitsu is working on a design-oriented approach, based on our Human-Centric policy. We recognize the importance of ensuring transparency. 2 Safety Today, discussions on the safety and risks of AI-powered products have just begun on a sector-by-sector basis, and it is premature to expect then to converge. Today’s discussion is not about the safety requirements that apply to all AIs, but about which cases and sectors AI solutions should be implemented, in particular starting with high-priority areas. We would like to emphasize that the scope of the PL Directive should not be expanded to impose liability on AI-based technologies beyond those incorporated into the hardware. Such a change of scope could leave AI system developers with the responsibility for problems that they cannot have any control over, and could discourage industries from developing and using AI systems. 3 Remote biometrics identification Definition and correct understanding of ‘remote biometric identification’ needs clarification among stakeholders. The challenges with remote biometric identification technology, should be discussed separately to the question of its regulation, and without distinguishing between the three perspectives of remote biometrics identification (racial discrimination, abuse and privacy), which might be detrimental to the European market and industry. Personal data which biometrics use is already covered in the GDPR, and no new AI-specific regulation is needed. On the other hand, we recognize there is legal uncertainty amongst local regulations defining the use of biometric identification for country safety and security purposes. We strongly believe harmonization would be beneficial. We believe it is necessary to create a market environment in which companies that invest in protecting ethics, safety, and privacy do not have a price disadvantage in the market. 4 Fujitsu’s opinions on EC’s alternative options to the baseline scenario Fujitsu would like to stress the importance of balancing innovation and regulation. We called it an “AI legislative comfort zone” to overcome the lack of clarity about what is possible and what is not with AI solutions. We support the Commission's proposal to prioritize high-risk AI applications following a risk-based approach based on the existing legislation and standards in sectors. In this sense “Option 4”, a combination of soft law, voluntary labelling schemes and EU legislation, establishing mandatory requirements for certain types of AI applications, could be the way forward to tackle the AI related challenges flexibly. Labels and standards for AI that are discussed at European level, should be constantly reviewed in cooperation with the international standards bodies, governments and other organizations representing industries, consumers and civil society. 5 Conclusion Fujitsu strongly encourages the European Commission to pursue an effective AI approach and strategy for the European market, which is able to play a leading role at a global level in strong cooperation and alignment with the Japanese Government. We remain convinced that a step-by-step approach, based on the definition of concrete cases and risks, is the baseline. A combination of different regulatory tools should be the way forward in order to ensure sufficient flexibility and, at the same time, provide clear rules.
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Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici), Lucie Mattera (Cabinet of Commissioner Pierre Moscovici) and

23 Jan 2018 · Commission's digital tax proposals: informative exchange of views. Multinationals concerned about impact of change