Comment by Small Business Standards (SBS)

Small Business Standards (SBS) would like to thank the European Commission for the opportunity to provide feedback on the proposal for a European Act on Artificial Intelligence (“referred to as AI Act”). After consultations with its members, SBS welcomes the European Commission’s initiative to drive forward Artificial Intelligence as one of the main pillars for digital transformation. – Conformity assessments will be too costly. This may put a burden on AI innovation as they bound financial and human resources of SMEs: The conformity assessment and certification procedure are estimated at around 5k – 7k€ according to the EC Impact Assessment, which seems unrealistic. Costs are likely to be substantially higher due: Total costs = external consultancy + internal costs + auditing cost (5k-7k €). [...] Moreover, certification schemes and conformity assessment for AI will duplicate the burden that is already put on SMEs with certification schemes for cybersecurity6. This hampers the SMEs’ ability to innovate. We strongly suggest that the regulators move away from this approach towards a more SME-friendly approach and avoid duplication of requirements and assessments.