Overall position. We support the proposal and welcome its coverage of AI companions and chatbots. However, its AI provisions are the weakest part. They lean on rules written for social media, and they carry exemptions and presumptions of compliance that apply nowhere else. Children's rights under Article 24 of the Charter and UNCRC General Comment No. 25 should be stated explicitly in the text.
AP
AI & Partners
Company · Netherlands · EU Transparency Register 932923493617-89
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1210 companies & groups on this site, they rank #459 by legislative files engaged, a count of participation, not a measure of influence.
2
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2024
in the register since
Declares membership of
- European AI Alliance: https://futurium.ec.europa.eu/en/european-ai-alliance
- AI 4 Belgium: https://altai.ai4belgium.be/
- OCEANIS: https://ethicsstandards.org/
- ML Commons: https://mlcommons.org/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Companies & groups
- Registered as
- AI & Partners, B.V. (AI & Partners)
- Head office
- Amsterdam, Netherlands
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
AI & Partners filed 3 positions between 12 Mar 2026 and 13 Oct 2026, across 3 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
Feedback on the Draft Commission Implementing Regulation (Ares(2026)2709234) Article 2 Model access scope is overbroad. The phrase "all levels of access granted to employees" sets an inconsistent, provider-dependent standard.
AI & Partners supports the draft Implementing Regulation under Articles 75c and 75d of the AI Act. The AI Office needs clear procedures before its first non-compliance decisions, and building on competition and DMA practice is the right approach. However, the draft protects efficiency more consistently than the rights of defence (Charter Arts 41, 47, 48) and legal certainty. We ask for the following changes. 1.
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Everything on this page comes from AI & Partners’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.