ACCIS contributes input into the European Commission’s Call For Evidence on the Digital Omnibus
The Digital package on simplification, which is scheduled for release on 19 November, is a flagship initiative of this Commission that is meant to bring to life its commitment to reducing the regulatory burden on businesses in the sphere of digital policy. In ACCIS’s...
ACCIS provides a response to the European Commission’s public consultation on the Digital Fairness Act
ACCIS appreciates the framing of the consultation questionnaire in the sense that it openly asks stakeholders whether and how consumer laws can be simplified in order to reduce the burden for businesses while maintaining the same level of consumer protection. In that...
ACCIS response to the European Commission’s public consultation on high-risk AI systems
In our response we explain that credit information suppliers are using AI for a number of different use cases ranging from KYC and anti-fraud processes, data filtering (not high-risk) all the way to producing credit scores (high-risk). At the same time, we underline...
ACCIS input into the CNIL Consultation on its reference framework for credit and the treatment of personal data.
ACCIS provided input into the French Data Protection Authority – CNIL – consultation on a reference framework for credit, “Un projet de référentiel sur l’octroi de crédit” due to the importance of the topic and the contribution made by the French DPA. This is despite...
ACCIS response to consultation on European Commission’s guidelines for an AI system definition
In our response, ACCIS argues that logistic regression (LR) is a simple statistical method distinct from artificial intelligence (AI) and should not be regulated as such under the AI Act. Unlike AI, LR lacks advanced capabilities like learning, reasoning, or complex...
ACCIS response to the EDPB’s Guidelines 1/2024 on processing of personal data based on Article 6(1)(f) GDPR – Legitimate interest
In our response to the EDPB Guidelines on legitimate interest, we highlight areas of agreement as well as sections where further clarification or amendment may be beneficial to ensure a balanced application of legitimate interest provisions in the context of consumer...
ACCIS response to targeted consultation on AI in financial services
In our response, ACCIS notes that credit reference agencies are exploring the use of AI to help lenders evaluate the creditworthiness of individuals and businesses, as well as to establish credit scores. We highlight that AI's ability to analyse vast and complex...
ACCIS response to the European Commission’s call for evidence on the GDPR
In this response, we express concerns about perceived imbalances in GDPR enforcement. We also note that the absence of clear guidance exacerbates the situation, especially in cases where the GDPR falls short in providing necessary clarity. Members of ACCIS assert that...
Joint Industry Statement on AI Definition
In this industry statement on the AI definition, a collaborative effort signed by ACCIS and various prominent industry financial services, we emphasize that traditional, statistical techniques used in credit scoring - e.g. logistic regression - warrant regulatory...
ACCIS feedback on the European Commission’s proposal on Financial Data Access (FIDA)
In our feedback paper on the European Commission’s proposal on Financial Data Access (FIDA), we state that the proposed framework represents a positive step toward responsible and innovative financial services within the European Union. However, there are crucial...