Ended with Response
Ended with Response

Response to the European Commission White Paper on Artificial Intelligence

Public consultation towards a European approach for excellence and trust

About this consultation

Aiming to promote the uptake of artificial intelligence (AI) while at the same time, addressing the risks associated with its use, the European Commission has proposed a White Paper with policy and regulatory options “towards an ecosystem for excellence and trust”. This document was published on 19 February 2020, along with an online survey, focusing on three distinct topics:

  1. Specific actions for the support, development and uptake of AI across the EU economy and public administration;
  2. Options for a future regulatory framework on AI;
  3. Safety and liability aspects on AI (as outlined in the relevant report)


As digital technology becomes an ever more central part of every aspect of people’s lives, people should be able to trust it. Artificial Intelligence will change our lives by improving healthcare (e.g. making diagnosis more precise, enabling better prevention of diseases), increasing the efficiency of farming, contributing to climate change mitigation and adaptation, improving the efficiency of production systems through predictive maintenance, increasing the security of Europeans, and in many other ways that we can only begin to imagine.

At the same time, Artificial Intelligence (AI) entails a number of potential risks, such as risks to safety, gender-based or other kinds of discrimination, opaque decision-making, or intrusion in our private lives.

Proposed changes

The current public consultation comes along with the White Paper on Artificial Intelligence - A European Approach aimed to foster a European ecosystem of excellence and trust in AI and a Report on the safety and liability aspects of AI. The White Paper proposes:

  • Measures that will streamline research, foster collaboration between Member States and increase investment into AI development and deployment;
  • Policy options for a future EU regulatory framework that would determine the types of legal requirements that would apply to relevant actors, with a particular focus on high-risk applications.

Consultation questions

These are the key consultation questions from the European Commission that IOSH has contributed to:

Section 1 - An ecosystem of excellence

  • Are there any other actions to strengthen the research and innovation community that should be given a priority?

Section 2 - An ecosystem of trust

  • In your opinion, how important are the following concerns about AI; Do you have any other concerns about AI that are not mentioned above?
  • Do you think that the concerns expressed above can be addressed by applicable EU legislation? If not, do you think that there should be specific new rules for AI systems?
  • If you think that new rules are necessary for AI system, do you agree that the introduction of new compulsory requirements should be limited to high-risk applications; If you wish, please indicate the AI application or use that is most concerning (“high-risk”) from your perspective.
  • What is the best way to ensure that AI is trustworthy, secure and in respect of European values and rules?

Section 3 – Safety and liability implications of AI, IoT and robotics

  • The current product safety legislation already supports an extended concept of safety protecting against all kind of risks arising from the product according to its use. However, which particular risks stemming from the use of artificial intelligence do you think should be further spelled out to provide more legal certainty?
  • Do you think that the safety legislative framework should consider new risk assessment procedures for products subject to important changes during their lifetime?

Read IOSH's response

For more information, please download IOSH's consultation response references.