Response by the Montreal AI Ethics Institute to the European Commission's Whitepaper on AI

In February 2020, the European Commission (EC) published a white paper entitled, On Artificial Intelligence - A European approach to excellence and trust. This paper outlines the EC's policy options for the promotion and adoption of artificial intelligence (AI) in the European Union. The Montreal AI Ethics Institute (MAIEI) reviewed this paper and published a response addressing the EC's plans to build an "ecosystem of excellence" and an "ecosystem of trust," as well as the safety and liability implications of AI, the internet of things (IoT), and robotics. MAIEI provides 15 recommendations in relation to the sections outlined above, including: 1) focus efforts on the research and innovation community, member states, and the private sector; 2) create alignment between trading partners' policies and EU policies; 3) analyze the gaps in the ecosystem between theoretical frameworks and approaches to building trustworthy AI; 4) focus on coordination and policy alignment; 5) focus on mechanisms that promote private and secure sharing of data; 6) create a network of AI research excellence centres to strengthen the research and innovation community; 7) promote knowledge transfer and develop AI expertise through Digital Innovation Hubs; 8) add nuance to the discussion regarding the opacity of AI systems; 9) create a process for individuals to appeal an AI system's decision or output; 10) implement new rules and strengthen existing regulations; 11) ban the use of facial recognition technology; 12) hold all AI systems to similar standards and compulsory requirements; 13) ensure biometric identification systems fulfill the purpose for which they are implemented; 14) implement a voluntary labelling system for systems that are not considered high-risk; 15) appoint individuals to the oversight process who understand AI systems well and are able to communicate potential risks.