CDT Europe has submitted its feedback to the European Commission’s public consultation on high-risk artificial intelligence (AI) systems. The organization’s input focuses on the obligations set out in the AI Act for providers and deployers of AI systems that are classified as high-risk, either because they are important for product safety or have a significant effect on people’s health, safety, and fundamental rights.
The European Commission sought public input to help clarify these obligations and determine which AI systems should be considered high-risk. The responses from this consultation will inform the guidelines for classifying high-risk AI systems, as required by the AI Act.
In its submission, CDT Europe identified several examples of problematic AI systems that it believes should be categorized as high-risk due to their disproportionate impact on fundamental rights. The organization also emphasized the need for thorough risk assessments, particularly Fundamental Rights Impact Assessments for certain deployers of high-risk AI. It provided recommendations on how these assessments could complement existing evaluation processes.
Additionally, CDT Europe underlined the importance of ensuring that requirements in the AI Act—such as access to remedies and the right to an explanation—are effective and meaningful for individuals affected by high-risk AI systems.
“Besides, we stressed the importance of meaningful risk assessments, in particular the Fundamental Rights Impact Assessment required of certain deployers of high-risk AI, and provided feedback on how complementarity with existing assessments can be ensured. We also reiterated the necessity to ensure that the AI Act’s obligations to ensure access to remedies, such as the right to an explanation, will be effective and impactful for individuals,” stated CDT Europe in its response.
The full submission is available online.