Last Friday, July 18th, Homo Digitalis submitted detailed input to two public consultations launched by the European Commission.
The first consultation focused on collecting targeted input from stakeholders regarding the implementation of the AI Act (2024/1689) rules for high-risk AI systems. According to Article 6(5) of the AI Act, the Commission must publish guidelines on the practical implementation of the high-risk classification rules by February 2, 2026, accompanied by a list of practical examples of both high-risk and non-high-risk AI systems. Additionally, Article 96(1)(a) requires the Commission to provide guidelines on the application of obligations and responsibilities for high-risk AI systems, including those across the AI value chain, as defined in Article 25. In its submission, Homo Digitalis provided practical examples of AI systems from Greece and other countries, and highlighted key issues that should be clarified in both the classification and compliance guidelines.
The second consultation addressed the EU Data Strategy. Its three goals are to: 1) boost investment in data technologies and promote data sharing through voluntary or funded initiatives; 2) streamline existing rules and develop data tools to reduce administrative burdens; and 3) shape an international data strategy that ensures safeguards for data transfers outside the EU and encourages data inflows into the EU.
In its response, Homo Digitalis raised strong concerns about potential undermining of personal data protection under the pretext of simplification, flexibility, and competitiveness. The organisation reaffirmed its position that fundamental rights must be strengthened through the use of new technologies and rejected the framing of existing legal frameworks as a barrier to innovation. According to Homo Digitalis, the challenges lie primarily in the lack of enforcement and resources, not the laws themselves.
You can read our full submission for the first consultation here.
We thank the drafting team, Stavrina Chousou, Niki Georgakopoulou, Sofia Antonopoulou, and Eleftherios Chelioudakis, for their valuable contributions.
You can read our full submission for the second consultation here, edited by our Executive Director, Eleftherios Chelioudakis.