The European DIGITAL SME Alliance (DIGITAL SME) welcomes and supports the work of the European Commission on Artificial Intelligence. Due to the increased importance of AI and its role in transforming European Businesses, DIGITAL SME pays increased attention to the Artificial Intelligence legislative framework. In this respect, DIGITAL SME is monitoring AI standardisation activities and is actively discussing with policy makers, politicians, standardisers, and other stakeholders to provide SMEs feedback on Europe’s aspirations of leadership in AI. One important topic in the EC draft AI standardisation request is conformity assessment. DIGITAL SME has highlighted its concern about the high costs associated with conformity assessments. Because of that:

1. It is essential that SMEs are involved in the development of standards used for conformity assessment. DIGITAL SME would like to stress the need to include in the standardisation request in developing standards to support conformity assessment processes.
2. European Standardisation Organisations (ESOs) should consider the impact regarding the costs entailed when verification, validation and associated methodologies for conformity assessment are applied in practice, in particular the impact on SMEs.
3. Furthermore, the ESOs should consider the operationalisation of those standards and the achievability of related technical tests so that they do not involve prohibitive costs by default (e.g., some of the aspects can only be theoretically tested or tested on large data sets, thus far-reaching for SMEs)
4. As a practical implementation toward inclusiveness, DIGITAL SME suggests that ESOs:
   • report about conformity assessment costs for SMEs.
   • run consultations on drafts with SBS WG Digitalisation and DIGITAL SME Focus Group AI so that SMEs are properly informed even if they do not participate in the ESOS or in the NSOs.
   • report about SME participation at the national and EU level