The European Association of Co-operative Banks (EACB) participated with great interest in the Commission consultation on the White Paper on Artificial Intelligence (AI). The EACB and its members in principle share the Commission view about an EU coordinated action plan and the need of an "ecosystem of excellence" and an "ecosystem of trust" concerning AI in the context of global competition.
However, such an approach has to balance the benefits and (potential) risks of AI in the context of economic development. In our perception, possible risks are more often related to the service as such than to AI technology itself. Especially for highly regulated industries such as financial services, there are already various regulations existing from consumer protection via operational and ITC risk management to general data protection regulation (GDPR) and anti-discrimination regulations.
Therefore, the approach to define "high-risk industries" only from the perspective of AI would cause fragmented silos, but no better management of technological risks. We are in favors of a risk-based approach concerning defined products or services, if there is an evidence for additional risk caused by AI, by no additional and fragmented regulation of already regulated industries in Europe.
Any initiative should be based on the European principles of a market economy, self-regulation, subsidiary and proportionality. As European banks have to compete in a global market and especially co-opeartive banks are serving the local European economy also in times of crisis, any additional regulation - if needed - has to protect the business model of banks in Europe including such of the co-operative banks.