The EACB is pleased to contribute to the European Commission’s AI Omnibus proposal. While welcoming the Commission’s aim to simplify the AI Act, the EACB stresses that several targeted adjustments are essential to ensure a workable, predictable and innovation friendly framework for cooperative banks.
A key priority for the EACB is to carve out the ‘stop the clock’ provision (Art. 113) and adopt it as a standalone measure. With high risk AI requirements becoming applicable on 2 August 2026, institutions need early certainty. The current proposal, which links a shorter deadline to a discretionary Commission decision, creates legal uncertainty and makes long term planning nearly impossible. The EACB therefore recommends deleting references to the Commission’s decision power and setting a single, clear application date for both Annex I and Annex III.
Beyond timing, the EACB proposes several clarifications to ensure coherence and proportionality. These include:
- explicitly excluding long standing statistical methods such as logistic regression from the definition of an ‘AI system’;
- maintaining the AI literacy article as originally drafted;
- clarifying requirements on the processing of special categories of data for bias detection;
- aligning the interpretation of ‘machine based’ with DORA to avoid regulatory inconsistencies; and
- providing greater certainty on responsibilities for AI embedded in ICT services or used only for analytical support functions.
These targeted improvements would help deliver a more predictable and proportionate regulatory environment, allowing co operative banks to continue innovating while upholding strong safeguards for customers and the financial system.