APDSI - Associação para a Promoção e Desenvolvimento da Sociedade da Informação
NGO · Portugal
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
3
positions filed
in the 639 files tracked
2
legislative files
of 639 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
APDSI - Associação para a Promoção e Desenvolvimento da Sociedade da Informação filed 3 positions between 10 Sept 2020 and 15 Jun 2026, across 2 of the 639 legislative files tracked here, attaching a full position paper 2 times.
The APDSI Association for the Promotion and Development of the Information Society welcomes the opportunity to provide input in the framework of the European Commission’s initiative on the future Digital Networks Act.
Filed in Portuguese · English published by the European Commission
1. Clarify the balance of responsibilities between AI-providers, distributors and users, especially for general purpose APIs and open source models: As explained above, the AIA does not sufficiently distinguish between the responsibilities of AI users when performing the role of distributor and the responsibilities of providers towards their consumers.
Filed in Portuguese · English published by the European Commission
● 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
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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