Letter to MEPs to further improve EU AI Act

13-05-2022
ECNL calls for standardised impact assessments and stakeholder engagement.

ECNL asks Members of the European Parliament to submit two amendments to the Artificial Intelligence Act. Specifically, we call for :

  1. Standardised methodology to underpin impact assessments;
  2. An advisory group composed of relevant external stakeholders (including CSOs and representatives of affected groups) in the structure of the EU AI Board and its supervisory tasks.

See the full text of the letter below:

 

Dear Members of the EU Parliament,

The time to act is now. Please submit the following two amendments to the EU AI Act to make it truly trustworthy, agile, inclusive and supportive of innovation. 

1. Include standardised methodology to underpin impact assessments

We are calling on the Members of the EU Parliament to include in the EU AI Act meaningful fundamental rights impact assessment requirements for AI systems development and deployment. 

In the amendments, we propose a set of overall criteria that should always underpin an impact assessment and we call on the Commission to develop and adopt a more detailed and standardised methodology for the whole impact assessment process. Such a methodology should include, as a minimum, a basic module assessment for all providers and users except high-risk AI; and a detailed module, for high-risk AI providers and users. This methodology should also include space for engagement and consultation with external stakeholders and publication of the key findings.

The business sector is already getting ready for such standardised assessments. Is the EU ready? 

Read more details in our proposed amendments here.

2. Ensure stakeholders’ participation in the AI Act

We are pleased to see that the IMCO-LIBE Report acknowledges the importance of involving stakeholders and civil society organisations in the AI Act’s governance and implementation. The report largely reflects our overall advocacy to include opportunities for relevant external stakeholders and civil society to contribute to the tasks of the relevant EU and national authorities reviewing and implementing the AI Act - see more here.

See more details in our proposed amendments here.

In line with the strengthening of stakeholders and civil society’s participation in the AI Act, we call on the Members of the EU Parliament to include an advisory group composed of relevant external stakeholders (including civil society organisations and representatives of affected groups) in the structure of the EU AI Board and its supervisory tasks.

We believe that setting up an advisory group would streamline multi-stakeholder engagement within the Board: first, it would allow quicker feedback routes to the Board regarding the application and implementation of the AI Act. Furthermore, it could assist and advise on the way to reach out, e.g., to marginalised or non-organised groups impacted by AI systems in a meaningful way. The advisory group will thus serve as a ‘bridge’ between the Board and broader civil society and other stakeholders.

In other words: the establishment of an advisory group of external stakeholders and CSOs to the AI Board will help operationalise all the well-received amendments in the IMCO-LIBE Report about meaningful stakeholder engagement and mitigate the risk that consultations with relevant stakeholders are reduced to mere box-ticking exercises.

 

Thank you for safeguarding our future!