2021/0106(COD) · In Force
403 submissions from 343 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 437 submissions on this file. Shown here: the 403 from organizations. Not shown: 19 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 15 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
235 submissions from industry — companies and their trade associations — against 98 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.4 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 2 submissions here repeat 2 texts word for word and are folded into them.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 14 Jun 2020 — it ran from 20 Feb 2020.
How it got here
Showing 25 of 153 submissions on this page · page 2 of 2 · 403 across the file. Search the whole file
· · filed 19 Jul 2021 · source
Consumer Reports applauds the European Union for putting forth a legal framework that can regulate algorithms and artificial intelligence in a systematic and comprehensive manner. While many of these algorithms and their applications are not new, they have real potential to harm the fundamental rights of EU citizens.
The proposal for an EU AI Act of 21 April 2021 Hildebrandt commentary 19 July 2021 Ref. Ares(2021)4651780 - 19/07/2021 A brief commentary by Mireille Hildebrandt 1 The Architecture of the AIA 1 1.1 Overview 1 1.2 Terminology 2 2 Issues 3 2.1 Prohibited practices 3 2.2 High risk systems 4 2.3 Transparency obligations for certain AI systems 6 2.4 Harmonisation 6 3 Enforcement, remedies, individual rights, oversight…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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.
Attached please find Google’s views on the European Commission’s proposal on the Artificial Intelligence Act. We thank the Commission for the opportunity to share feedback, and look forward to continue engaging in the debate on the proportionate, risk-based AI regulation in Europe.
Fon [phone removed] [email removed] www.dsv-europa.de Transparenzregister Nr. 917393784-31 Deutsche Sozialversicherung Europavertretung Rue d’Arlon 50 B-1000 Bruxelles Die öffentliche Konsultation der EUKommission zum Vorschlag eines „Gesetzes über Künstliche Intelligenz“, COM (2021)206 final Stellungnahme der Deutschen Sozialversicherung vom 14.07.2021 Die Deutsche Rentenversicherung Bund (DRV Bund), die Deutsche…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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.
· · filed 14 Jul 2021 · source
The International Center for Ethics in the Sciences and Humanities (IZEW) of the University of Tuebingen (Germany) welcomes the EU proposal on the regulation of AI. To achieve a comprehensive and effective result, we seek to contribute to the consultation process with the following suggestions: 1.
European Commission Piet Mondriaanlaan 54 3812 GV Amersfoort Postbus 1671 3800 BR Amersfoort T (033) 460 08 00 F (033) 460 08 50 www.agentschaptelecom.nl Agentschap Telecom Reactie Openbare raadpleging Van M. Vrieze T Datum 14 juli 2021 AI Act Agentschap Telecom Feedback Bijlagen - Algemeen Agentschap Telecom is de autoriteit in het digitale domein en is de uitvoerder en toezichthouder op digitale infrastructuur in…
Filed in Dutch · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 bias in criminal justice, manipulating public opinion and enabling mass surveillance practices.
Raising standards for consumers POSITION PAPER ANEC comments on the European Commission proposal for an Artificial Intelligence Act (Regulation laying down harmonised rules on artificial intelligence and amending certain Union legislative acts) s COM(2021) 206 final, 2021/0106 (COD) Contact: [name removed] [email removed] ANEC is supported financially by the European Union & EFTA Ref: ANEC-DIGITAL-2021-G-071 July…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 standard specifications.
These are the contributions of the SPANISH CENTRE OF REPROGRATIVE DERECHOS EGDPI (CEDRO) to the proposal for a Regulation COM (2021) 206 on Artificial Intelligence Act. Cedro is an intellectual property rights management organisation established in Spain, authorised by the Ministry of Culture and Sport, in accordance with Spanish law, to carry out its objectives.
Filed in Spanish · English published by the European Commission
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 trusted through a sound and appropriate regulatory framework on AI.
· · filed 13 Jul 2021 · source
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 innovation, pioneering new products and services.
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 strong horizontal cross-sector regulation of AI.
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 RULES ON ARTIFICIAL INTELLIGENCE (ARTIFICIAL INTELLIGENCE ACT) AND AMENDING CERTAIN UNION LEGISLATIVE ACTS.
This feedback comes from the Norwegian Open AI Lab, an AI research centre based at the Norwegian University of Science and Technology (NTNU) in Trondheim. The Norwegian Open AI Lab is a partnership organization with partners from the Norwegian private and public sector.
· · filed 9 Jul 2021 · source
The Teachers' union of Ireland (TUI) welcomes the publication of the AI Regulation as it sets the ground for the first comprehensive EU regulation on Artificial Intelligence to ensure a controlled development of AI tools in education and address the risks connected to their use by teachers, academic, other education personnel and students.
ENHET DATUM Enheten för Avtalsfrågor 2021-07-07 DIARIENUMMER Ref. Ares(2021)4470078 - 09/07/2021 20210182 HANDLÄGGARE ERT DATUM ER REFERENS Linda Larsson Ert datum Er referens Europeiska kommissionen Remiss av Europeiska kommissionens förslag till förordning om harmoniserade regler för artificiell intelligens LO har i detta skede gjort en första bedömning av förslaget till AIförordning och har valt att lämna några…
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 9 Jul 2021 · source
AI will have a significant impact on Europe’s competitiveness and wellbeing of citizens. It is crucial to support the development of European AI technologies and applications both financially, and by building an interoperable, horizontal ecosystem of European state-of-the-art data and HPC infrastructures.
· · filed 8 Jul 2021 · source
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.
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 demonstrating compliance with the regulatory requirements.
AI has the potential to contribute significantly in several areas such as increased economic growth as well as solutions to environmental and social challenges. There are examples of AI enabling better diagnoses of diseases, reducing traffic accidents, streamlining industrial production, developing new drugs, and shortening red tape. At the same time, the risks of AI need to be considered.
· · filed 2 Jul 2021 · source
Artificial Intelligence in healthcare is already a reality. Healthcare providers have embedded the technology into their workflows and decision-making processes. The introduction of AI in healthcare has brought improvements for patients, providers, payers, other healthcare stakeholders, and society at large, also in the fight against the COVID-19 pandemic.
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 base for the regulation of AI.
The City of Stockholm welcomes the regulation laying down harmonised rules on artificial intelligence and amending certain union legislative acts. However, certain concerns arise with the current proposal for the Artificial Intelligence Act: 1. There is a need to clearly specify which types of legal requirements that are mandatory for the different authorities, organisations and companies (etc) concerned. 2.
I. General comments: 1. On a general assessment, it can be said that the proposed Artificial Intelligence (AI) Regulation falls far short of the expectations of consumer protection organisations and also of the Commission’s own objective of making AI in something where citizens feel confident.
Filed in Portuguese · English published by the European Commission
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 vocational training and thus makes them subject to special approval conditions.
· · filed 24 Jun 2021 · source
ONE OF THE DIMENSIONS OF AI IS THAT OF LIABILITY FOR DAMAGE CAUSED BY ROBOTS. IN ORDER TO DETERMINE THE OWNERSHIP OF A ROBOT OR THE MORTGAGE CHARGES THAT MAY EXIST ON THE, ASI AS ULTIMATELY RESPONSIBLE FOR THE DAMAGE CAUSED BY IT, SPANISH REGISTRARS BELIEVE THAT ROBOTS, AI AND ITS COMPONENTS SHOULD BE ENTERED IN THE LEGAL REGISTERS.
Filed in Spanish · English published by the European Commission
WKÖ-Position Paper on the Regulatory Framework for Artificial Intelligence Technological development is progressing and AI applications are becoming increasingly diverse, so their own uniform rules are to be welcomed in principle. In order to guarantee a level playing field, each AI system in the internal market must comply with the same requirements.
Filed in German · English published by the European Commission
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, providing, or using AI systems, especially those classified as high-risk systems.
Engine B welcomes the EC’s proposals to harmonise the regulation of AI across the Union. Standardisation will help ensure that negative impacts of AI on humans are consistently prevented while supporting technology firms to engage confidently on a level and consistent playing field.
The regulation fails to address the crucial role that social partners and collective bargaining play in the deployment of new technologies at the workplace. Participation of workers’ representatives in the development, implementation and governance of AI systems at the workplace is key to ensure the best protection of workers’ rights. Collective bargaining is an essential tool to address technological change.
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. Standards play an essential role in helping to achieve a broader acceptance of AI systems and bolster trust in them.
The attached document presents a critical summary and assessment of the proposed legislation prepared by the Chairs of the Artificial and Natural Intelligence Toulouse Institute (ANITI). The document discusses the limitations of the definition of AI used in the proposed regulation and the potential impact of the regulation in the geography of innovation and artificial intelligence and the competitiveness of Europe…
· · filed 14 Jun 2021 · source
Alliance VITA would like to urge the Commission to take more account, in its proposal for a Regulation on Artificial Intelligence, of a number of key principles relating to respect for fundamental rights and the dignity of individuals, in particular in the field of medicine and healthcare. It should be borne in mind that the rise of Artificielle Intelligence (AI) has led to many new challenges in this regard.
Filed in French · English published by the European Commission
AWARENESS OF PUBLIC INTELLIGENCE Version 1.0 Ref. Ares(2022)124194 - 07/01/2022 www.publicintelligence.org Public Intelligence Empowering Accountable and Ethical Innovations. Contributors Author Editors Abigail Holt Keeley Crockett Ana Chubinidze Nenad Rava David Young Sherin Mathew Elaine Feeney David Young Parisa Murtza Stefan Janusz Claire Taylor Sam Datta-Paulin Page 2 About The Author Sherin Mathew Founder &…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SAZKA Group submission to the EC public consultation on Artificial Intelligence – ethical and legal requirements (“EC proposal on the Artificial Intelligence Act”1) 1. Short intro SAZKA Group (SG) is one of Europe’s fastest growing lottery companies, primarily focused on national lottery games, instant lotteries and online lotteries with a secondary focus on digital gambling and sports betting; SG has leading market…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 12 May 2021 · source
The proposed regulation is an excellent initiative but needs improvement to be applicable to the cases for which it is intended. The definition of AI The definition of AI in Article 3.1 is contingent on the current state of the art. The Commission has the right to update the list of techniques given in Annex I (Article 4) but on the basis of what criteria would it do so?
· · filed 5 May 2021 · source
Please find below our feedback on the AI impact assessment. - More classical algorithms such as linear regression have been around for many, many years and have almost never caused any damage or frustration. Artificial intelligence is a modern term that scares people, but in reality it is only an applied technology (mathematical, statistical,...) on data.
· · filed 27 Apr 2021 · source
Unfortunately, standardisation measures are still not very common in the life sciences R&D. In the same time, more and more AI solutions are finding their way into life science research and development. Therefore, standardisation between AI and the life sciences should be harmonised too.
September 10, 2020 Consumer Technology Association Comments on European Commission “Inception Impact Assessment” on Artificial Intelligence Ref. Ares(2020)3896535 The Consumer Technology Association® (“CTA”)®1 respectfully submits these comments in response to the European Commission (“Commission”) Inception Impact Assessment2 (“the Impact Assessment”) analyzing the potential impact of adopting sweeping new…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 10 Sept 2020 · source
CDT welcomes the opportunity to provide input to the Commission's choice of regulatory approaches for artificial intelligence. We respectfully offer the following suggestions: 1) Be more precise: No single approach to regulating “AI” will make sense in all scenarios.
· · filed 10 Sept 2020 · source
ETNO welcomes the Commission’s objective to foster the uptake of Artificial Intelligence technologies and products that abide by European ethical norms, legal requirements, and fundamental rights. Today, no specific EU legal framework to regulate AI exists.
Artificial Intelligence (AI) can offer significant benefits not just to businesses, but also to consumers and society. Retailers and wholesalers are central actors in the supply chain and are in daily contact with Europe’s 450 million consumers.
Smart government approaches to regulation will play an important role in boosting public confidence and ensuring that AI is used responsibly, while also encouraging innovation. However, it is important that a proportionate, risk-based approach is taken - balancing potential harms with the social and economic benefits that will be created by AI.
Feedback for the EU Commission Inception Impact Assessment towards a “Proposal for a Regulation of the European Parliament and the Council laying down requirements for Artificial Intelligence” Denise Amram – Giovanni Comandé *LIDER Lab, DIRPOLIS Institute, Scuola Superiore Sant’Anna (Pisa- Italy) Table of contents: 1. Introduction. 2. Selecting Option 4 with option 3.c as a baseline (Option 4+3.c) 3.
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 goals of Amsterdam coalition 'AI Technology for People'.
· · filed 10 Sept 2020 · source
Department of Computer Science (DIKU) at the University of Copenhagen (UCPH) welcomes the opportunity to provide feedback to the European Commission’s (EC) Inception Impact Assessment for a Proposal for a legal act laying down requirements for Artificial Intelligence. EC is proposing four policy options. Below, we provide feedback on each option and some general considerations.
Clifford Chance LLP welcomes the opportunity to respond to the European Commission's inception impact assessment on a "Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence".
The IEEE SA appreciates the opportunity to respond to the Commission’s IIA. As a resource, we suggest our publication, Ethically Aligned Design, First Edition. The law chapter provides commentary about how the law should respond to a number of specific ethical and legal challenges raised by the development and deployment of AIS and the benefits/risks of the incorporation of AIS into a society’s legal system.
· · filed 10 Sept 2020 · source
First of all, APPLiA would like to point out that the concept of Artificial Intelligence is still not well defined and as such we oppose regulating it, as there may be completely different understandings of AI by various actors on the market. A similar situation applies regarding the lack of definition of “high” / ”low” risk.
COCIR welcomes the inception impact assessment by the European Commission on ethical and legal requirements for Artificial Intelligence (AI) and the opportunity to provide feedback. Continuing our engagement in this area, and following the earlier consultation on the AI White Paper, COCIR is pleased to share its experience and expertise on the use of AI within healthcare.
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.
FEEDBACK OF THE ELECTRONIC PRIVACY INFORMATION CENTER to the EUROPEAN COMMISSION INCEPTION IMPACT STATEMENT Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence Sep.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Center for Data Innovation is please to submit feedback to the European Commission’s roadmap titled “Inception Impact Assessment: Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence." The European Commission’s white paper on AI, published in February 2020, argues that AI may cause harm and existing legislation consumer protection, product…
· · filed 10 Sept 2020 · source
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.
techUK welcomes the opportunity to respond to the Inception Impact Assessment proposed by the European Commission on the proposed legal act on Artificial Intelligence. Please find below our comments on the legislative options outlined: Option 1- EU “soft law” (non-legislative) approach techUK supports a soft law approach to AI and building upon existing initiatives, such as the AI HLEG assessment list and the…
· · filed 10 Sept 2020 · source
FFA welcomes EC’s initiative to encourage the ethical and responsible development of artificial intelligence (AI) in the EU. AI offers economic, societal and competitive advantages to European businesses and citizens. The appropriate ethical and legal framework, based on European values, in line with the Charter of Fundamental Rights, will allow for the deployment of improved AI.
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 AI.
Microsoft appreciates the opportunity to respond to the European Commission’s Inception Impact Assessment (“IIA”) on its proposal for a legal act setting out requirements for artificial intelligence (“AI”). We support the Commission’s goal of ensuring that AI evolves in a manner that respects EU values and fundamental rights.
PARC-000237-2020 Assunto: Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence Requerente: Comissão Europeia - CNECT.A.2 I. Comentários na generalidade: 1.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 comments.
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.
The European Banking Federation (EBF) welcomes the opportunity to respond to the European Commission’s Consultation on its Inception Impact Assessment (IIA) on a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence (AI). Please see the attached document for our comments.
By contributing to the initial impact assessment on artificial intelligence (AI), TECH IN France wishes to continue its involvement in the work and reflections of the European Commission as part of its AI strategy.
Filed in French · English published by the European Commission
· · filed 10 Sept 2020 · source
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 protect European citizens & businesses.
ADIGITAL CONTRIBUTION European Commission Public Consultation on Artificial intelligence- ethical and legal requirements 1. Scope Adigital welcomes the opportunity to respond to the Commission’s Inception Impact Assessment on the proposed legislative initiative on AI.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 10 Sept 2020 · source
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 organisations (RPOs), are important users and producers of data.
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 legislation.
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 company highlighted its support for this important discussion and Twilio’s willingness to contribute constructively.
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.
· · filed 10 Sept 2020 · source
“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.
Syntec Numérique supports the Commission’s ambition to stimulate the development and uptake of AI and new technologies, while ensuring that potential risks are adequately addressed. In order to ensure consistency with existing sectoral legislation, the future proposal for the regulation of AI will have to take into account existing EU rules and which already cover the application of AI (protection of fundamental…
Filed in French · English published by the European Commission
We are grateful to the European Commission for this opportunity to provide input towards proposals for legislative action on requirements for Artificial Intelligence (AI). We encourage EU policymakers to pursue a collaborative and inclusive approach for preparation of their proposals including the perspective from global industry.
Wkład Związku Pracodawców Branży Internetowej IAB Polska w ramach konsultacji Komisji Europejskiej dot. sztucznej inteligencji 1. Zakres: ○ Przede wszystkim ostrzegamy Komisję Europejską przed rozszerzeniem zakresu przyszłej regulacji w sprawie Sztucznej Inteligencji (AI) na szeroko zdefiniowaną kategorię "automatycznego podejmowania decyzji".
Filed in Polish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SIENNA, a European Horizon 2020-funded project, is looking into ethical, legal and human rights issues and is developing ethical guidelines for human genomics, human enhancement and AI & robotics. We welcome the language that puts fundamental rights and societal values first.
SHERPA is an EU-funded Horizon 2020 project that focuses on ethical and human rights aspects of smart information systems (artificial intelligence and big data analytics). We welcome language in this Inception Impact Assessment that prioritises protection of human rights and recognises both the benefits and harms of AI.
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 not new nor is information gathering for a better more objective decision process (e.g.
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).
The Association of German Technical Inspection Agencies 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 social benefits, but equally entails significant risks to the safety, health and privacy of users.
Filed in German · English published by the European Commission
10 SEPTEMBER 2020 DIGITALEUROPE input to Commission Inception Impact Assessment on AI DIGITALEUROPE supports the Commission in its ambition to stimulate the development and uptake of AI and new technologies, while ensuring that any potentially linked risks are adequately addressed. In this paper, we provide our comments to the public consultation on the published Inception Impact Assessment1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Implementing an open European digital future Ibec response to the European Commission White Paper on Artificial Intelligence Contents Key messages............................................................................................................
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
This is a common statement of the Augmented Law Institute of EDHEC Business School (for the list of Professors composing this group, please click on the link: https://www.edhec.edu/en/legaledhec-research-centre#dexp_tab_item_2063327793). An extended version is attached. In this summary here we report just our main conclusions.
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 one-size-fits-all mandates.
· · filed 10 Sept 2020 · source
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 also too much complexity and over-regulation should be avoided.
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 processing and extracting value out of data, automating decisions and extracting insights.
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.
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 technology to thrive.
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 at international level to ensure consistency for our manufacturers CEMA is in favour of Option 1, as it offers the…
· · filed 10 Sept 2020 · source
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.
Bitkom welcomes the open consultation approach of the AI Inception Impact Assessment of Assessment of the European Commission for a proposal for a legal act of the European Parliament and the European Council regarding the „requirements for Artificial Intelligence“ (Future regulatory framework for AI in the European Union).
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 the benefit of the citizens, the economic actors and the Member States by enabling new products, services and…
First and foremost, we would like express our support for the European Commission's efforts to establish an appropriate regulatory framework for AI. In establishing such a framework, one should both look at existing laws and regulations and determine if they are 'fit for purpose' for a world with AI as well as consider establishing new rules where current legislation is not adequate.
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 scenario – i.e.
Comment of the German Insurance Association (GDV) ID-number 6437280268-55 on the Roadmap for a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence Gesamtverband der Deutschen Versicherungswirtschaft e. V.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 approach and focus on high-risk IA-based applications.
· · filed 10 Sept 2020 · source
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 other societal challenges.
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 consider the legal and policy measures needed for the regulation of AI in criminal justice.
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.
A clear and widely understood definition of artificial intelligence will be crucial for the effectiveness of any future regulatory framework. Therefore, we are committed to the definition of artificial intelligence as the so-called automatic decision making system. The definition of artificial intelligence would be contrary to the direction proposed by the Commission in its White Paper.
Filed in Polish · English published by the European Commission
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 rights when we use AI applications.
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 companies and foster trust in AI applica-tions.
10 September 2020 Requirements for Artificial Intelligence ITI views on the European Commission Inception Impact Assessment The Information Technology Industry Council (ITI) welcomes the publication of the Inception Impact Assessment (IIA) on Requirements for Artificial Intelligence, and appreciates the opportunity to provide comments building on our contribution to the February 2020 White Paper on Artificial…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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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 businesses”. We agree that AI “can contribute to a wide array of economic and societal benefits”.
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 they choose, with the range and services they want, always at prices they can afford.
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● Scope: ○ I do not seem appropriate to expand the scope of the future AI Regulation for the open category of “automated decision-making”. This would go against the initial idea reflected in the AI White Paper, which proposes to focus on and be based on the risk and double criteria for sectoral AI technologies and application/use.
Filed in Portuguese · English published by the European Commission
Association for Financial Markets in Europe Consultation Response Inception Impact Assessment - Proposal for a Legal Act of the European Parliament and the Council Laying Down Requirements for Artificial Intelligence 10 September 2020 The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on INCEPTION IMPACT ASSESSMENT - PROPOSAL FOR A LEGAL ACT OF THE EUROPEAN PARLIAMENT AND THE…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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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.
Visa Response to the European Commission IIA on Requirements for Artificial Intelligence September 2020 1 About Visa Visa welcomes the opportunity to respond to the European Commission’s Artificial Intelligence White Paper. Our mission is to connect the world through the most innovative, reliable, and secure payments network – enabling individuals, businesses, and economies to thrive.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Workday Comments on the European Commission Inception Impact Assessment for a “Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence” September 10, 2020 Introduction Workday is pleased to submit comments on the Inception Impact Assessment (IIA) for a “Proposal for a legal act of the European Parliament and the Council laying down requirements for…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EDiMA welcomes the opportunity to provide feedback on this Roadmap. EDiMA and its members can offer insight into the interplay between the technical aspects of AI and its broader impact on the economy and society, and are committed to maximising the benefits of AI for Europe. While the current and potential benefits of AI are numerous, concerns about AI are important and legitimate, and should not be discounted.
PRAGUE, 10 SEPTEMBER 2020 Response to the European Commission’s inception impact assessment on AI ethical and legal requirements Smart government approaches to regulation will play an important role in boosting public confidence and ensuring that AI is used responsibly, while also encouraging innovation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 attached position paper. FERMA brings together 22 risk management associations in 21 countries.
“Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence” Comments on Inception Impact Assessment September 10, 2020 AI Utilization Strategy Task Force Committee on Digital Economy Keidanren Page 2 At the same time, AI may generate new safety risks for users and third parties, which are not yet explicitly tackled clearly by the product safety…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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ACEA welcomes the opportunity to comment on this Inception Impact Assessment on a potential initiative on AI. AI represents a key technological area for the entire automotive value-chain and EU industry at large. We therefore endorse Commission’s plans to mobilise EU resources and R&D efforts, as no Member State alone could support our global competitive standing in this field.
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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 critical infrastructures, we at EnBW operate multiple self-developed AI services already productively.
EGMF comments on the EC roadmap on proposal for a legal act on AI requirements Brussels, 9 September 2020 EGMF represents European manufacturers of garden, landscaping, forestry and turf maintenance equipment. EGMF is pleased to provide its comments on the new Roadmap on proposal for a legal act on AI requirements.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 efficient, more predictable and more sustainable, making easier for our customers to interact with us and to play a more active…
The Good Lobby welcomes the opportunity of providing feedback on this legislative initiative. Without a doubt, Artificial Intelligence (AI) is already changing the world, its potential impacts having long been discussed and analysed.
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 supports the development of a solid AI European approach based on European values.
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A clear and widely understood definition of AI is essential for the effectiveness of the future regulatory framework. As the Commission’s White Paper on AI described the main elements of AI as data and algorithms, the original impact assessment seeks to suggest too broad scope for future regulation of AI.
Filed in Romanian · English published by the European Commission
Vodafone welcome the opportunity to respond to the European Commission Roadmap Inception Impact Assessment (IIA) on the proposal for a legal act of the European Parliament and council laying down the requirements for AI to operate within the single market.
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In the view of the Deutsches Gesetzliche Unfallversicherung e.V. (DGUV), a legal framework that can adequately address cases of the use of Artificial Intelligence (AI) is in principle desirable, but it should be examined as a matter of priority whether the existing general legal framework, i.e. not specifically focused on AI, is not sufficient in most cases to deal adequately with cases of AI.
Filed in German · English published by the European Commission
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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 development and uptake of Artificial Intelligence (AI) and new technologies.
NL AIC welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the “Artificial intelligence – ethical and legal requirements” legislative proposal. 1. We support the Commission’s mission to foster the development and uptake of safe and lawful AI that offers legal certainty, a favourable investment climate and an innovation optimum across the Digital Single Market…
NL AIC welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the “Artificial intelligence – ethical and legal requirements” legislative proposal. 1. We support the Commission’s mission to foster the development and uptake of safe and lawful AI that offers legal certainty, a favourable investment climate and an innovation optimum across the Digital Single Market…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
NL AIC welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the “Artificial intelligence – ethical and legal requirements” legislative proposal. 1. We support the Commission’s mission to foster the development and uptake of safe and lawful AI that offers legal certainty, a favourable investment climate and an innovation optimum across the Digital Single Market…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 – envisages a new policy option which foresees an EU legislative instrument establishing mandatory requirements for all AI…
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STM welcomes the ambitions of the European Commission to lead globally in promoting the uptake of Artificial Intelligence whilst ensuring that the highest levels of excellence and trust are respected and delivered to European consumers and businesses.
Google welcomes the opportunity to provide further input to the European Commission’s deliberations around AI governance. The promise of AI to deliver societal benefits cannot be realised without well-founded public trust in AI’s use.
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 biometrics invoke severe fundamental rights implications, and therefore should be in scope. 3.
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 clinical guidelines), and in our clinical roles as medical professionals (e.g.
The HDE welcomes the Commission’s balanced Inception Impact Assessment, which explicitly takes into account the interests of the economic operators concerned, in particular SMEs, and compares the potential burden of regulation with its benefits. The explicit focus on legislative coherence and consistency in the areas of liability, product safety and fundamental rights protection is also positive.
Filed in German · English published by the European Commission
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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 1 For the construction machinery sector, we do not see any benefits of additional requirements for AI-enhanced subsystems in…
Response to EC roadmap: Artificial intelligence – ethical and legal requirements Ref. Ares(2020)4700626 - 09/09/2020 Philips welcomes the opportunity to provide feedback on the roadmap for AI ethical and legal requirements. As rightly pointed in the roadmap and the AI White Paper, AI is developing fast and has the potential to improve and reshape healthcare.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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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 Assessment considers several options for regulating AI applications at EU level.
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 mitigating the risks associated with AI applications.
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 reduce burdensome compliance costs derived from legal fragmentation.
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 functions, comfort functions, advanced driver-assistance systems warnings, connectivity systems, infotainment systems, etc.
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, double-criterion for sectorial and application/use-based AI technologies.
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 of the political guidelines and lines of action for this congress.
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A EUROPEAN LEGAL ACT LAYING DOWN REQUIREMENTS FOR ARTIFICIAL INTELLIGENCE Response of Federation of German Consumer Organisations (vzbv) to the public consultation on the inception impact assessment for the “Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence” 8. September 2020 Impressum Verbraucherzentrale Bundesverband e.V.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 outlined here are dealt with more substantially in our White Paper response, uploaded here.
CK Hutchison’s comments on the roadmap for regulation of Artificial Intelligence The Commission has published its roadmap on Artificial Intelligence (AI), listing the regulatory options available, from doing nothing, issuing guidelines and voluntary labelling, to mandatory regulation of some or all AI applications. We agree with the need for a regulatory framework for AI.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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 workers AI literacy, promote and increase safeguarding of workers rights, of workers protection, consider…
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Software AG highly welcomes the Commission's objective to increase trust in AI thus fostering not only its use but also its development in Europe. We share the Commission's view that while AI can do much good, some of its uses and applications may cause both material and immaterial harm.
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 instrument establishing mandatory requirements for all applications.
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. affecting the Machinery Directive, the General Product Safety Directive or the product liability regime.
VDMA (German Mechanical Engineering Industry Association) 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 for Artificial Intelligence. AI will be a core enabling technology for many sectors of European industry. Therefore, VDMA supports an European approach.
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, concerns with AI are an extension of concerns with data use overall.
BusinessEurope welcomes the positive tone of the Commission’s White Paper acknowledging the many opportunities that AI can bring to Europe’s economy and society. We support the Commission in its venture to build ecosystems of excellence and trust in Europe for Artificial Intelligence (AI).
Policy analysts and policymakers are responding to AI as both a threat to human rights and as a potential savour of humanity from discrimination. This response rests on two questionable ideas. The first is that AI’s supposed human-like intelligence could give it a mind or a ‘will’.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.