Recommendations to the European Commission on Its “Draft AI Ethics Guidelines for Trustworthy AI”

ITIF’s Center for Data Innovation submitted feedback to the European Commission’s High-Level Expert Group (HLEG) on AI on its draft AI Ethics Guidelines for Trustworthy AI. The guidelines aim to provide concrete guidance on how to implement and operationalize “trustworthy AI” systems that “maximize the benefits of AI while minimizing its risks.” While this goal is worthwhile, the guidelines have five main problems: 1) they present an overall negative tone towards AI; 2) they overlook the importance of EU leadership on AI adoption as a means of influencing global AI ethics; 3) they incorrectly suggest that developing a European AI ethics governance system will allow the EU to significantly differentiate its AI solutions, thereby gaining global market share; 4) they inaccurately frame AI as a technology that requires ethical tradeoffs, instead of one that can be used to improve ethical behavior; and 5) they propose principles such as transparency and explainability that would limit AI development.