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...
ACCIS statement on several CJEU cases
In this statement, we outline our views on several CJEU cases that can shape the regulatory framework for the provision of credit referencing services in the internal EU market. In our opinion, cross-border access to credit databases will only be meaningful if the...
ACCIS response to public targeted consultation on Open Finance
In our response to the European Commission’s targeted consultation on Open Finance, we state that Open finance should complement what exists and works well in the market today: it should add value to existing markets and systems for the sharing and reuse of financial...
ACCIS response to EDPB’s Guidelines on calculation of fines
In our response to the EDPB’s Guidelines on calculation of fines, we note that the EDPB appears to emphasise setting GDPR fines at a level that effectively deters future non-compliance whilst we would prefer similar attention to ensuring the proportionality of GDPR...
ACCIS feedback on the European Commission’s proposal on the EU Data Act
In our feedback document on the proposed EU Data Act, ACCIS broadly welcomes the EU Data Act as it creates a fairer, more innovative, and more competitive data economy in Europe. We are however unclear as to the stated harmonising objective of the Regulation. The GDPR...