We, the undersigned organisations, have followed the work of the EU Institutions on Artificial Intelligence, supporting the European Commission’s original intent for a risk-based approach to AI.
AI will constitute a key technology for economic development in the European Union, and its integration into industrial processes is a priority for the EU and its Member States. The AI Act has the opportunity to set out a first-of-its-kind legislative framework on Artificial Intelligence and will shape how AI is developed and deployed in Europe.
The European Parliament has so far suggested many important modifications to the original proposals, and we applaud the constructive spirit that has been prevalent during the negotiations on a Draft Report. At the same time, we remain concerned by the possibility of significantly deviating from the AI Act’s original proposal and goals to establish a risk-based approach to AI that fosters innovation and uptake in Europe. In particular, we urge the European Parliament to ensure that any possible new requirements and amendments to the Act are introduced taking into account their technical feasibility, impact on legal certainty, and the ability of AI developers, deployers, and users to comply with them. As the Rapporteurs and Shadow Rapporteurs work to finalise a compromise text to form the European Parliament position, we strongly urge them to consider the following key principles and take more time for deliberation, ensuring that the AI Act:
- Maintains the risk-based approach of the original proposal while defining “high-risk” in a way that reflects it;
- Allocates responsibilities properly along the value chain and allows contractual freedom to do so;
- Includes in Annex III only use-cases that are truly high-risk;
- Uses a definition of AI that is recognised by industry, is in line with OECD work, and does not include non-AI tools;
- Establishes legal certainty for the extraterritorial application of the Act’s scope and effect on the EU’s international partners;
- Ensures that the AI Act does not overlap or create competing obligations with existing legislation; and
- Avoids uncertainty for further investment, trade, and innovation.
Our organisations represent European and non-European designers, developers, deployers, and users of Artificial Intelligence. We strongly recommend that the European Parliament agrees on a position that recognises the importance of AI for economic and societal development and empowers the EU to harness the opportunities created by Artificial Intelligence while protecting EU fundamental rights.
The AI Act is a momentous opportunity for Europe to lead in developing a legislative framework that supports innovation and places the EU as the global leader in trustworthy AI. We urge the European Parliament to take the necessary time to finalize a draft report that supports AI innovation and uptake in Europe.
Signatories:
ACEA – European Automobile Manufacturers Association
AFNUM – The French Alliance of Digital Industries
BSA | The Software Alliance
BusinessEurope – The Confederation of European Business
CECIMO – European Association of the Machine Tool Industries and related Manufacturing Technologies
EuroCommerce
Euralarm
EGMF – European Garden Machinery Federation
INFOBALT Lithuania
Insurance Europe
ITI – Information Technology Industry Council
LIKTA – Latvian Information and Communications Technology Association
MedTech Europe
SEPE – Federation of Hellenic ICT Enterprises
