In our feedback document, ACCIS acknowledges the Commission’s efforts to address both the benefits and challenges of AI. We believe, however, that more work is needed to strike the right balance between promoting innovation and protecting European citizens and their rights. We fear that the current draft adopts a disproportionate approach that could curtail the use of socially beneficial applications of AI/ML, in particular as regards creditworthiness assessments and credit scoring.
In the paper, we identify three main critical issues in the draft Act:
1. the definition of AI systems should be narrowed so that it does not include low risk, understandable and explainable techniques such as logistic regression;
2. AI for credit scoring and creditworthiness assessments should not be deemed high-risk because borrowers are already adequately protected by existing legislation and regulations;
3. the concept of creditworthiness should be clarified;