Homo Digitalis participated in AI Office’s consultation on Prohibited Practices under the AI Act
In November 2024, the European Commission’s Artificial Intelligence (AI) Office launched a consultation on AI Act prohibitions and AI system definition.
The guidelines under development will help national competent authorities as well as providers and deployers in complying with the AI Act’s rules on such AI practices ahead of the application of the relevant provisions on 2 February 2025.
Homo Digitalis participated in this public consultation process by submitting our input, in an attempt to highlight challenges and provide further clarity on practical aspects and use cases.
The authors’ team of our public consultation is composed of our Director on Human Rights & Artificial Intelligence, Lamprini Gyftokosta and our members Sophia Antonopoulou and Stavrina Chousou.
You can read our input here.
Stay tuned, since our dedicated report on the AI Act and its provisions on Prohibited Practices is to be published soon!
We publish our Second AI Act Study on market surveillance authorities and the AI governance ecosystem
Today Homo Digitalis publishes its second study on Regulation 2024/1689, the now well-known AI Act, entitled “AI Act: Analysis of Provisions for AI Governance and Competent Market Surveillance Authorities“.
The writing team for the study consists of Homo Digitalis’ Director of Human Rights and AI, Lamprini Gyftokosta, and our member Niki Georgakopoulou.
The purpose of this Homo Digitalis analysis is to highlight some of the critical issues raised by the implementation of the AI governance system provisions, taking into account national structures as well as the civil society perspective.
More specifically, in this analysis we answer the following questions:
- What governance structure does the Regulation propose for AI?
- What does the concept of ‘market surveillance authority’ mean for the AI Regulation?
- What is in Regulation 2019/1020 and why should we consider its provisions together with the AI Act?
- Which Greek authorities meet the requirements set out in the two Regulations and why?
- What governance models have been adopted or are under discussion in other jurisdictions at this time?
- What are our main concerns?
- What are our main suggestions for improvement?
We recall that on 12 November, the Department for Digital Government took the first official step in implementing the AI Act by publishing the list of national authorities for the protection of fundamental rights. These principles include: The Data Protection Authority, the Ombudsman, the Communications Privacy Authority and the National Human Rights Commission.
In this regard, as early as 25 October, with our first Study “Analysis and proposals for the incorporation of the provisions on impact assessment on fundamental rights in Greece“, we had already presented detailed proposals on this issue. If you did not have time to read our Study, we invite you to see the one-page summary we prepared, specifically for the National Fundamental Rights Authorities.
The Ministry’s publication was only the first step. The next critical obligation is the institutional design of the market surveillance authorities, which must be completed by August 2, 2025, in accordance with Article 113 of the Regulation.
The second Study that we are publishing today is precisely intended to assist the Ministry of Digital Governance, which has the task of carrying out the difficult task of synthesizing this ecosystem in Greece, but also, with our detailed analyses and arguments, to help mature the public debate and enable more civil society organizations to actively participate in it.
We are actively involved in the enforcement of the AI Act in Greece
On Tuesday 12 November, the Ministry of Digital Governance published the list of national authorities and bodies that enforce or supervise compliance with EU obligations to protect fundamental rights under Article 77 of the AI Regulation, appointing the Hellenic Authority for Communication Security and Privacy (ADAE), the Greek Data Protection Authority (DPA), the Greek National Commission for Human Rights (GNCHR) and the Greek Ombudsman (Ombudsman).
Already on 25 October, Homo Digitalis with its study “Analysis and proposals for the incorporation of the provisions on fundamental rights impacts assessment of the AI Act in Greece” had developed in detail its position on this issue and the related provisions.
If you did not have time to read the full text of our study, we have prepared a one-page summary of the National Fundamental Rights Authorities here.
We underline that this publication by the Ministry of Digital Governance was both the first obligation for the implementation of the AI Act at the national level and the first step in the creation of an effective national AI governance and oversight system. A second and most important obligation is that of the institutional design of the market surveillance authorities which, according to Article 113(b) of the AI Regulation, should be completed by August 2, 2025. By then, the notifying authorities should also be appointed.
Homo Digitalis has been researching this issue for months now and we will soon publish our detailed analysis!
Our purpose? To assist decision makers with our expertise in the relevant issues, as well as to equip other Civil Society organizations in Greece with arguments and knowledge!
We publish our first detailed study of the AI Act and the provisions of the FRIAs
Homo Digitalis publishes today its first Study on the European Regulation on Artificial Intelligence entitled “Artificial Intelligence Act: Analysis and proposals for the incorporation of the provisions on fundamental rights impact assessment in Greece”.
The authors of this first Study are our member Sophia Antonopoulou and Homo Digitalis’ Director of Human Rights & Artificial Intelligence, Lamprini Gyftokosta.
The Study is the first of a series of analyses that we will be publishing in the near future on various important provisions of the AI Regulation, which aim both to inform decision makers in Greece about important provisions of the AI Act in order to assist in its successful implementation, and to frame the public debate on AI in Greece by providing specific arguments and proposals.
The focus of the first Homo Digitalis Study is to highlight some critical issues raised by the implementation of the provisions on AI in the Fundamental Rights (FRR), from the perspective of civil society. Besides, it aims to contribute constructively to the public debate by proposing concrete solutions for an effective impact assessment process with regard to high-risk AI systems.
In summary, the main conclusions of the Study include the following concerns:
- The exclusion from the obligation to carry out NRAs of AI systems used exclusively by private services.
- The complete lack of sanctions for those who violate the provisions on TDRs.
- The ambiguities and interpretative gaps regarding how to carry out an ERA, the updating of data and the re-conducting of an ERA, the risk assessment and proposed measures, the notification of the market surveillance authority and the exemptions from such notification of the market surveillance authority; and
- The lack of transparency in the use of AI systems and the preparation of SIAs in the areas of law enforcement, migration and asylum management and border control.
It also summarises the proposals for improvement in five key points that are crucial for the effective protection of fundamental rights against any violations of AI systems:
- It is proposed to exercise discretion under Article 99(2) and to introduce sanctions for non-compliance with the provisions on AI practices. It is further proposed that the relevant sanctions should be on the same scale as those for non-compliance with the prohibition of AI practices under Article 99(3) of the Regulation.
- It is proposed to establish detailed governance arrangements with clear procedures for handling complaints and appeals and to ensure stakeholder participation in the Greek law that will incorporate the Regulation.
- Amend Law 4780/2021, the provisions of which govern the functioning of the National Human Rights Commission to assume the role under Article 77 of the Regulation under certain conditions.
- In addition to the template for conducting a NCHR, it is necessary to develop guidelines, including an extensive analysis of Recital 96,Articles 6(2), 27, 43, 46, 49 and 77 of the AI Regulation.
You can read the Homo Digitalis Study in detail here.
Elpida Vamvakas' speech at the 52nd Book Festival is now available on video!
Homo Digitalis has the great honor to be present at the 52nd Book Festival that took place at Pedion Tou Areos.
Specifically, on Thursday, September 19, our co-founder and President Elpida Vamvaka participated as a speaker in a round table organized at the main stage of the festival by the Association of Book Publishers (S.E.B.) & the Hellenic Comics Academy on the topic “Is art written with AI?”
The discussion was moderated by Panagiotis Papageorgiou (Lawyer, Member of the Greek Comics Academy) and Dimitris Doukoglou (illustrator, presenter, stand-up comedian). Other roundtable speakers include Vassilis Vlahokyrikakos (Associate Professor of Human-Computer Interaction) , Abraham Kawa (Author, Translator & Theorist of Culture) and George Nathaniel (IT and Management Consultant).
The videographer of the event is Dimitrios Bournous and we would like to thank him for the material he shared with us in this regard.
Watch the full statement from Hope here.
Homo Digitalis participates in the European Commission Plenary meeting on the AI Act
September ended with important meetings for Homo Digitalis in the context of the European Regulation on Artificial Intelligence (AI Act) at European level!
Specifically, on September 30th we participated online in the first meeting organized by the AI Office of the European Commission regarding the development of a Code of Practice for General-Purpose AI Systems “Kick-off Plenary: Code of Practice for General-Purpose AI”.
Homo Digitalis has been selected to participate in the relevant working groups that will be formed in order to collaborate with Civil Society organisations and other stakeholders in the coming months in this mission to develop this Code.
We were represented at the online meeting by our Director for AI and Human Rights Lamprini Gyftokosta and our co-founder Eleftherios Chelioudakis.
We co-organize and participate in the Tech & Society Summit in Brussels
The Tech and Society Summit is approaching and will take place on Tuesday, 1st October in Brussels! This exciting conference, co-organized by EDRi in collaboration with Homo Digitalis and over 40 other organizations, will bring together leading experts, policymakers, and human rights advocates to discuss the intersection of technology and societal impacts in Europe. The summit will cover critical issues, ranging from digital rights and climate change to AI regulations, contributing to the shaping of a fair and equitable digital future for all.
We are excited that Eleftherios Chelioudakis will represent Homo Digitalis as a speaker at the session Visionary Roundtable: Building an EU Digital Enforcement Strategy. With important laws such as the Digital Markets Act (DMA), Digital Services Act (DSA), and AI Act, Eleftherios will highlight the actions of Homo Digitalis, discussing how these regulations can effectively protect rights and boost Europe’s competitiveness in the digital space.
Additionally, Homo Digitalis has been invited to participate in the session Fundamental Rights in Focus: Joint Efforts for Spyware Regulation in the EU, co-organized by the Centre for Democracy & Technology Europe (CDT Europe) and Amnesty International. In this session, key policymakers and civil society representatives will meet to explore ways to regulate spyware in the EU, and we will discuss our experiences from the latest related developments in Greece.
You can read more about the Tech and Society Summit and view its program here.
Homo Digitalis met with representatives of the Ministry of Digital Governance for the national implementation of the AI Act
September started with important meetings for Homo Digitalis in the context of the European Regulation on Artificial Intelligence (AI Act) at national level!
Specifically, on September 4, we had the honor to meet with the Ministry of Digital Governance and its representatives Mr. Vassilis Karkatzounis and Mr. Papagiotis Papaspiliopoulos in order to exchange views on the implementation of the AI Act in Greece. We were represented at the meeting by our Director for AI and Human Rights issues Lamprini Gyftokosta and our co-founder Eleftherios Chelioudakis. We would like to thank the representatives of the Ministry for their positive response to our request for a meeting, the and the very fruitful dialogue!
Translated with DeepL.com (free version)
Homo Digitalis participates in the European Commission's Open Consultation on General-Purpose AI
Yesterday, 18/9 Homo Digitalis submitted its responses to the European Commission’s Open Consultation under the title “FUTURE-PROOF AI ACT: TRUSTWORTHY GENERAL-PURPOSE AI”. The consultation covered issues concerning the future implementation of the AI ACT legislation and how to make the use of General-Purpose AI models trustworthy.
Homo Digitalis’ position paper on the Consultation was prepared by our organisation’s AI & Human Rights Director, Lamprini Gyftokosta and our member Tania Skrapaliori
You can read our statement here.