Response by the Montreal AI Ethics Institute to the European Commission's Whitepaper on AI

Policy alignment across sectors is critical: MAIEI recommends focusing coordination efforts on the research community, member states, and the private sector, emphasizing that a fragmented approach to AI governance will undermine Europe's ability to build trustworthy AI systems effectively.

Transparency and explainability require nuance: Rather than treating AI opacity as a binary problem, MAIEI calls for more sophisticated discussion about when and how transparency is necessary, recognizing that different AI applications have different requirements for interpretability.

Citizens need recourse mechanisms: The institute specifically recommends creating formal processes for individuals to appeal AI system decisions or outputs, establishing a fundamental right to challenge automated decisions that affect people's lives.

Research infrastructure must be strengthened: MAIEI proposes establishing a network of AI research excellence centers and Digital Innovation Hubs to build expertise and facilitate knowledge transfer, suggesting that Europe's competitive advantage depends on investing in human capacity alongside technology.

Facial recognition warrants special restrictions: The response recommends banning certain uses of facial recognition technology, indicating that some AI applications pose sufficient risks to warrant outright prohibition rather than regulation alone.