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