CONSULTATION RESPONSE
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AI inception impact assessment consultation: EBF response
BRUSSELS, 11 September 2020 – The European Banking Federation (EBF) submitted its view on the European Commission’s Consultation on its Inception Impact Assessment (IIA) on a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence (AI).
Artificial Intelligence can contribute to a wide array of economic and societal benefits across the entire spectrum of industries. For the European banking sector, AI provides significant opportunities that range from enhancing customer experience, improving financial inclusion, cybersecurity, and consumer protection, to strengthening risk management and process efficiency. Yet to realize these benefits, the EU regulatory environment needs to be fit for the use of AI and enable innovation, while providing legal certainty and maintaining a strong level of consumer protection.
With this regard, the EBF highlights the need to avoid any duplication of requirements or conflicting requirements for areas that are already regulated (through horizontal or sectoral legislation) in order to prevent additional burdens and legal uncertainties. As a general principle, we believe that any regulation should remain technology-neutral. Legal requirements should not apply to the underlying technology but to its application.
This is essential for AI development and uptake across industries, including in the financial sector. It is also crucial for the competitiveness of European firms globally.
The EBF response to the IIA builds upon our analysis in the response to the European Commission’s AI White Paper
For further information on our position on AI, please consult: EBF AI White Paper
For more information:
Liga Semane, Policy Adviser Data & Innovation, l.semane@ebf.eu
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]]>IIA large online platforms: EBF response
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30 June 2020: The European Banking Federation (EBF) welcomes the European Commission’s initiative to address the issues with regard to large online platforms with significant network effects acting as gate-keepers and welcomes the opportunity to respond to the published Inception Impact Assessment (IIA) on a possible ex-ante regulatory instrument.
We support the Commission’s assessment of both the positive aspects and the challenges presented by online platforms. There is a wide recognition that online platforms have been instrumental to the growth of digital markets and have helped spur both efficiency gains and innovation across the wider economy, including supporting SME engagement in the
digital economy.
At the same time, the nature of online platforms and the consequences of their growth and position in the modern digital economy has resulted in increasing concerns over how to ensure that digital markets remain conducive to fair competition and continue to generate the same opportunities and incentives for innovation in the future. We agree with the Commission that several platforms have developed particularly crucial roles, with the potential for their actions and decisions to have outsized effects on the European digital economy and to set “the parameters for future innovations, consumer choice and competition” across the Single Market.
We would, therefore, like to highlight in this response two particularly pressing issues, related to the role of data held by large online platforms and of technical infrastructure operated or controlled by large online platforms in the digital economy. These will also be expanded upon together with other points in our response to the Commission’s
consultation on the Digital Services Act Package.
Media contact:
Liga Semane, Data & Innovation – Policy Adviser – l.semaine@ebf.eu
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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