GATE INSTITUTE, SOFIA UNIVERSITY ST KLIMENT OHRIDSKI
GATE
The first Centre of Excellence (CoE) in Big Data and AI for Eastern Europe has been launched as ‘Big Data for Smart Society’ – GATE at Sofia University ‘St Kliment Ohridski’, Bulgaria.
ID: 253643250105-33
Lobbying Activity
Response to Apply AI Strategy
3 Jun 2025
GATE Institute Centre of Excellence for Big Data and Artificial Intelligence at Sofia University St. Kliment Ohridski welcomes the European Commissions Apply AI Strategy. We support its vision for responsible, human-centric, and effective AI deployment across sectors and public services in Europe. Our feedback highlights the importance of: - Strengthening the role of applied research organisations in bridging the gap between innovation and deployment; - Enhancing SME participation via Digital Innovation Hubs and Data Spaces; - Supporting local and regional AI ecosystems; - Encouraging open-source AI as a pathway to EU technological sovereignty; - Including real-world uptake indicators and regional experimentation in the implementation phase. Please find our full feedback document attached.
Read full responseResponse to Rules and conditions for the establishment and the operation of the interoperability regulatory sandboxes
13 Mar 2025
GATE Institute is Bulgarias first Centre of Excellence focused on Big Data and AI. The mission of GATE is to conduct Big Data and AI applied research, to develop innovations and to provide education in collaboration with government, industry, and entrepreneurs. GATE aims to nurture the next generation of well-educated professionals, create new business opportunities and generate societal impact in Bulgaria and Europe. The Institute is recognised for its work in AI, big data, and smart cities. Featuring among its pioneering initiatives is our Experimental Regulation and Policy Lab, which offers a sandbox environment and tools to support interdisciplinary development and testing of technologies and prototyping and modelling of new legal, ethical and policy solutions to meet contemporary technical, regulatory and market concerns. GATE Institute welcomes the opportunity to provide feedback on the Draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/903 of the European Parliament and of the Council, as regards the establishment and the operation of the interoperability regulatory sandboxes We appreciate the Commissions efforts in creating rules that would facilitate the establishment of safe space for experimentation and regulatory learning while maintaining the necessary safeguards for both participants and third parties. We do believe that sensible, result-driven and transparent framework for regulatory sandboxes is key for ensuring legal certainty and facilitating innovation. The term innovative is frequently referenced in the Interoperable Europe Act and the Draft Commission Implementing Regulation. We recommend clearer guidance on the interpretation of innovative due to its multifaceted nature, which can vary depending on context and objectives. The eligibility criteria for regulatory sandboxes are discussed, with a recommendation to better distinguish between eligibility criteria and conditions under Article 10 of the Draft Commission Implementing Regulation. Transparency in assessments conducted under Article 10(2) is also emphasised. There are notable differences in capacity between Member States, particularly in terms of resource constraints faced by Data Protection Authorities (DPAs) when implementing and enforcing the GDPR. We recommend additional measures to ensure fairer geographic representation and equal participation opportunities for all Member States. We also emphasise the need for strong technical support and expertise from the private sector for the success of interoperability regulatory sandboxes. The balance between general rights and obligations of participants and incentives for engaging in sandbox projects is considered misaligned. The standardisation of acquired knowledge is recommended to ensure greater consistency and clarity in documenting and sharing results from interoperability regulatory sandboxes. The format should be visually uniform and adhere to clear, standardised terminology and document structures.
Read full responseResponse to Establishment of the scientific panel of independent experts under the AI Act – implementing regulation
14 Nov 2024
GATE Institute, Bulgaria's first Centre of Excellence focused on Big Data and AI, welcomes the opportunity to provide its feedback on the Draft Commission Implementing Act laying down the rules for the application of Regulation (EU) 2024/1689 of the European Parliament and of the Council as regards the establishment of a scientific panel of independent experts in the field of artificial intelligence. We appreciate the Commission's efforts to create rules for a balanced, representative, and diverse panel of independent experts in AI. Despite the merits of the proposal, we have identified several limitations and weaknesses and have made recommendations for improvement. Firstly, we believe that the term 'scientific' should be interpreted broadly to include both technical and non-technical expertise in AI. This approach would allow the representation of experts with both practical and academic experience, ensuring a more comprehensive understanding of AI's multidimensional nature. The AI Act suggests that the panel should include independent experts selected based on up-to-date scientific or technical expertise in AI. However, neither Regulation (EU) 2024/1689 nor the proposed Commission Implementing Act specifies whether the pool of experts should be limited to individuals with doctoral degrees or postdoctoral experience in scientific disciplines. We recommend that the Commission adopts a broad interpretation of 'scientific' to include both technical and non-technical expertise in AI. We also emphasise the importance of multidisciplinarity and interdisciplinarity. The scope of scientific and technical areas should be expanded to explicitly include non-technical disciplines. The selection criteria should prioritize experts with knowledge from multiple domains, such as both computer science and social sciences or law. The Draft Commission Implementing Act lays down the need to ensure 'multidisciplinary adequate and up-to-date scientific or technical expertise', but it suffers from an implicit bias towards natural sciences, Additionally, the inclusion of references to fundamental rights and equality is necessary but insufficient. The list should be complemented by requirements for expertise in intellectual property rights, data governance, and risk management. Furthermore, the selection criteria should go beyond the current compute-centric metrics typical of AI governance models. This recommendation aligns with the forward-looking regulatory architecture of the AI Act and ensures that the panel's expertise is not limited to computational aspects alone. Regarding trade secrecy and confidentiality, the provisions on requests for assistance should clarify the scope of 'due regard' given to trade secrets and confidential business secrets. It is not clear whether the scope of the due regard should be limited to trade secrets or confidential business secrets of only providers of AI systems and general-purpose AI models or also of third parties. We also recommend expanding the requirements of independence to include independence vis-à-vis other actors, not just providers of AI systems or general-purpose AI models. This expansion is necessary to avoid conflicts of interest and ensure the panel's effectiveness. Specifically, the Draft Commission Implementing Act should consider independence with respect to undertakings that may have a personal stake in promoting tools and methodologies for evaluating capabilities of general-purpose AI models and systems. Lastly, the Draft Commission Implementing Act should address the practical aspects of the modalities of calls for support and advice more explicitly. It should clarify whether only national competent authorities or also other entities exercising official authority can make such requests. Additionally, it should address more explicitly the practical aspects of the modalities of these calls for support and advice. The full opinion is available in the attached file.
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