COMMENTS ON THE EU PROPOSAL FOR THE ARTIFICIAL INTELLIGENCE ACT

8 Pages Posted: 18 Nov 2021

See all articles by Anastasiya Kiseleva

Anastasiya Kiseleva

Vrije Universiteit Brussel (VUB); CY Cergy Paris Université

Date Written: August 05, 2021

Abstract

In April 2021, the European Commission issued its first legislative proposal to regulate AI: EC Proposal for the AI Act. The provided feedback described in the paper was submitted during the official procedure of public consultations.

I generally support the architecture and the ideas of the proposed AI Act. It is an impressive work and provides a great start for the legislative process. Highly welcome things are the risk-based and data-focusing approaches, level of specifications for the core requirements (transparency, human-oversight, data governance, risk management, record- keeping, accuracy, robustness, and security), the introduction of different roles for subjects involved in the AI life cycle with their relevant rights and obligations. The great achievement of the AI Act is the implementation of the proposed requirements into the existing conformity assessment procedures (or when there are no applicable existing procedures – the suggestion of similar ones).

Yet, I have discovered some areas of improval:

- the roles of the subjects who are affected by the decision made with the use of AI Systems shall be defined;
- the concept of AI user shall be clarified (especially in multi-stakeholder environment);
- 'transparency' terminology shall be used consistently;
- 'transparency-interpretability' requirement in article 13 shall be clarified;
- the hierarchy between transparency and the related concepts shall be defined - transparency as a legal principle and the other concepts as the measures supporting the principle;
- clarification on the concept of 'bias' is needed.

I explain each of the point in the text.

Keywords: AI Act, EC Proposal for the AI Act, AI Legal Framework, Accountability, Transparency, Interpretability, Explainability, High-Risk AI Applications, MDR, IVDR, Medical Devices, Healthcare, Regulatory Framework on AI

Suggested Citation

Kiseleva, Anastasiya, COMMENTS ON THE EU PROPOSAL FOR THE ARTIFICIAL INTELLIGENCE ACT (August 05, 2021). Available at SSRN: https://ssrn.com/abstract=3949585 or http://dx.doi.org/10.2139/ssrn.3949585

Anastasiya Kiseleva (Contact Author)

Vrije Universiteit Brussel (VUB) ( email )

Brussels
Belgium

CY Cergy Paris Université ( email )

paris
France

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