Developers Alliance

Developers Alliance welcomes the proposed Digital Omnibus. Key points: 1. AI developers will benefit from relying on legitimate interest for training and operating AI models. A practical risk-mitigation approach is better than impossible data-scrubbing mandates for special categories of data 2.

Developers Alliance welcomes the targeted simplification measures for the AI Act and call for further ambitious efforts to ease the regulatory burden for software developers. We particularly call for: 1. Feasible compliance deadlines, aligned with the availability of standards, and a 12-month extension for transparency obligations. 2.

Developers Alliance welcomes the opportunity to provide feedback on the AI Act proposal. We commend the objectives and the risk-based approach of the proposal. We call on the EU co-legislators, however, to address a series of critical issues so the regulation will be fit for purpose and to reduce the competitive disadvantage for European developers: - set legally clear definitions and limit the scope to clearly…

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.

Developers Alliance welcomes the proposed revision of the Cybersecurity Act, to streamline the governance of the EU cybersecurity policy and the harmonized certification framework. Key points: 1. Strengthen ENISAs mandate, to provide independent technical expertise throughout the legislative process, including the implementation and enforcement phases. 2.

Developers Alliance appreciates the opportunity to provide feedback on the European Commission’s proposal for a regulation on harmonized rules on fair access to and use of data (Data Act). The proposed approach is raising many legal and technical challenges, adding another layer of complexity to the EU regulatory landscape.

March 30 2021 Developers Alliance Position On The Digital Services Act (DSA) Founded in January 2012, the Developers Alliance is a global industry association that supports software developers as entrepreneurs, innovators, and creators. DevelopersAlliance.org In summary, the Developers Alliance supports a Digital Services Act that… …is a horizontal and harmonized framework. …provides legal clarity and certainty.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Developers Alliance welcomes the opportunity to provide its input on the IIA on Digital Services Act package. The future regulation governing the provision of online services in the EU should be fit-for-purpose and provide a clear and stable legal framework which will allow businesses to provide a diversity of products and services to consumers, in a safe way and with respect to fundamental rights.

The free flow of data and strengthening the use and re-use of data in certain sectors have great potential to drive increased economic and societal benefits, but it should be done entirely under a voluntary approach. We reiterate our strong recommendation to base any future framework on the principle of voluntary sharing of data between individuals or businesses, in full respect of contractual freedom.

Developers Alliance welcomes the opportunity to provide comments on the proposal for a regulation on horizontal cybersecurity requirements for products with digital elements (Cyber Resilience Act). The Cyber Resilience Act (CRA) imposes baseline cybersecurity requirements that can improve the level of security of digital products.

Developers Alliance welcomes the opportunity to respond to the call for evidence for an impact assessment on a legislative initiative for common cyber security rules for manufacturers and vendors of tangible and intangible digital products and ancillary services. Please find our comments in the attached document.

Our mission is to provide a collective voice for software developers and to represent their interests on matters affecting the software development ecosystem. From this perspective, we see the potential benefits of the DMA, but also predictable spillover effects on certain digital ecosystems, raising the cost of doing business for developers, as well as a negative impact on investment in the EU digital markets.

Developers Alliance welcomes the opportunity to provide its feedback on the IIA on ex-ante regulation for large online platforms, as part of the Digital Services Act package. Software developers, like other entrepreneurs, need a predictable regulatory environment. The proposed regulatory initiative raises concerns from this perspective.

Developers Alliance welcomes the opportunity to provide feedback on the proposal for a Regulation on Machinery Products. We limit our observations to elements implicating software and software developers. Software developers are contributing to technological solutions for more and more sophisticated machinery products.

Developers Alliance appreciates the opportunity to provide input to the consultation on the proposal for a Regulation on general product safety. Our comments are strictly limited to aspects related to software development, and in particular on the correlation with other relevant EU legislation and legislative proposals.

Developers Alliance welcomes the opportunity to provide feedback on the proposal for a regulation on preventing and combating child sexual abuse material (CSAM). EU lawmakers need to wisely balance the tradeoffs before implementing a de facto online surveillance system in the EU.

Developers Alliance welcomes the opportunity to provide feedback on the proposal for a Directive on liability for defective products. The proposal is revising the legal framework provided by the Product Liability Directive (PLD), extending the scope in regard to software, types of damages and changing the burden of proof and conditions for compensation claims.

In response to the European Commission’s announcement of their intention to introduce new legislation to govern the relationship between platforms and businesses, the Developers Alliance surveyed over 110 European-based developers and publishers on their experiences, in an effort to gain a more robust understanding on their relationship with platforms and examine the need for regulatory intervention.

The Developers Alliance welcomes the opportunity to provide feedback on the European Commission’s planned revision of the eIDAS Regulation. Developers Alliance advocates on behalf of software developers and the companies invested in their success, to support the industry’s continued growth and promote innovation. Please find attached our position paper.

Developers Alliance advocates on behalf of software developers and the companies invested in their success, to support the industrys continued growth and promote innovation. We recognize the proposal for a Directive on adapting non-contractual civil liability rules to artificial intelligence (AI Liability Directive - AILD) in relation to the implementation of the AI Act.