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VNG calls attention to feasibility of AI regulation

The EU wants to become a world leader in Artificial Intelligence (AI). The European Commission published a proposal for AI regulation to protect citizens and stimulate innovation. VNG figured out what this means for municipalities and comes with points of interest and recommendations.

VNG April 7, 2022

News press release

News press release

In terms of content, the regulation works with a risk approach that prescribes stricter requirements for high-risk systems such as benefits, critical infrastructure or identification. The VNG is mostly positive about the regulation. The risk approach and the uniform frameworks ensure that the regulation does what it is supposed to do, namely protect citizens and promote innovation.

However, we do have some generic concerns and concrete recommendations regarding the enforceability of the law.

Points of interest

  • Public values must be paramount in the development and deployment of AI, and these must be served by AI regulation.

  • Innovation is not an end in itself; it should never be more important than values and human rights.

  • The fundamental constitutional principles of the rule of law must remain guaranteed.

  • The definition of AI should not be narrowed to the point where it no longer includes cases such as the surcharge affair.

Recommendations

  • VNG urges the European Commission to clarify the division of roles between suppliers and users of AI technology, in line with the spirit of the law that "the developer pays.

  • VNG asks the European Commission to ensure that the administrative burden on municipalities is proportionate to the purpose of the AI Regulation, the protection of public values, and to offer support where necessary.

  • Finally, VNG calls on the European Commission to urgently include the perspective of feasibility, and to seek cooperation in this with municipalities and other implementers.

Advice to municipalities

When working with algorithms it is wise to make a clear distinction between developing algorithms yourself and purchasing a ready-made product and to make very conscious choices in this regard. When procuring a product it is important to watch out for the division of roles, so that the municipality does not unintentionally fall into the role of 'supplier' and get saddled with administrative burdens that actually belong to the product developer.

The VNG supports municipalities in this with the development of procurement and quality conditions and information models and standards, among other things, to provide suppliers with clarity on their requirements in terms of safety, public values and human rights.

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