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DOT Europe Open letter on AI Trilogue Negotiations: Call for Clarity and Innovation

BRUSSELS – 23 October 2023: DOT Europe has issued an open letter to trilogue negotiators concerning the Artificial Intelligence Act. We express concerns regarding recent developments in the AI Act and call for further clarifications to ensure it balances risk mitigation versus innovation.

Key takeaways from the letter:

  1. Clarify the exemption to Annex III: DOT Europe urges clarification regarding the notion of profiling to prevent an overly broad high-risk classification, stressing that profiling should only be “high-risk” when it has significant legal effects on individuals.
  2. Avoid arbitrary classifications: Policymakers should avoid introducing overlapping layers of obligations for foundation models and general purpose AI systems, ensuring they align with the risk-based approach.
  3. Unintended consequences: The letter highlights the potential unintended consequences of broad bans on low-risk technologies, particularly in the context of biometric categorization.
  4. Acknowledge the link between allocated responsibilities and limited liability.
  5. Consider technical aspects and user engagement in transparency provisions.
  6. Avoid overlap with the Copyright Directive: Caution is advised against introducing disproportionate obligations already covered by existing rules.

DOT Europe emphasizes its commitment to supporting trust and innovation in AI while urging policymakers to address these concerns in the ongoing AI Act trilogue negotiations.

Read the full letter here: DOT Europe Open Letter_AI Act Trilogues_23.10.2023

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