PromethEUs replies to the European Commission White Paper on Artificial Intelligence

The PromethEUs’ response to the European Commission White Paper is a joint effort of EsadeGeo, I-Com – The Institute for Competitiveness, and IOBE – The Foundation for Economic & Industrial Research

The White Paper was published on 18 February as a part of the Von der Leyen Commission’s new digital package – also including the Communications on Shaping Europe’s Digital Future and the European Strategy for Data – to promote European innovation in the area of AI while supporting the development and uptake of an ethical and trustworthy AI in the EU. According to the Commission, for Europe to fully seize the opportunities that AI offers, it must develop and strengthen the necessary industrial and technological capacities. As set out in the EU Strategy for Data, this also requires measures that will lead to the EU becoming a global data hub.

To foster an ecosystem of excellence, PromethEUs highlights the need for AI regulation to encourage most companies to adopt AI easily and at a competitive cost. Therefore, a clear understanding of different company needs should be acknowledged according to their position in the value chain. While the EU should strive to achieve better results in research and innovation, most companies, especially SMEs, would be either only or mainly AI users.

According to PromethEUs, both training and advice to SMEs should be key activities for AI specialized digital innovation hubs (DIHs). For this reason, foreseeing only one DIH per Member State may imply a sizeable geographical barrier for SMEs, especially in larger countries. A more distributed network of DIHs, providing expertise to SMEs in different regions, should be developed, possibly involving trade associations and larger AI technology players.

PromethEUs agrees on the need for a new European legislation, arguing in favor of a EU-wide, instead of a national, regulatory framework. Nevertheless, current legislation should apply whenever possible in order to avoid excessive market fragmentation and uncertainty, and a significant increase in compliance costs for companies, especially SMEs.

In PromethEUs’ view, AI applications should be compared with a human-based benchmark. It would not be realistic indeed to expect AI achieving an error-free perfection where, in the same field, that standard is not currently applied. This difficult to achieve requirement could greatly stifle innovation, especially from SMEs and new entrants.

Finally, PromethEUs draws attention to the risks that reforming the current EU legislative framework to better cover the hazards entailed in AI applications may generate. These could involve a serious fragmentation in the internal market between AI and non AI-based products, discriminating against the former. For this reason, while some amendments to the current legislation could be justified by better attributing responsibility in certain situations and providing legal certainty, we believe that such revisions should be limited and targeted to a well-defined scope.

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