• Proliferation of standards, records keeping, and conformity assessment can significantly impact SMEs ability to innovate in AI.

• European Standardisation Organisations (ESOs) should involve SMEs in the development of AI Standards. An inclusiveness fund for societal stakeholders, including SMEs is a step in the right direction.

• ESOs should constantly seek feedback of SMEs. SBS WG Digitalisation and DIGITAL SME Focus Group AI can facilitate a proper channel to inform and gather SME feedback.

Artificial Intelligence is an important topic for SMEs and a technology that impacts SMEs across all sectors. The draft AI standardisation request contains a list of standards that the European Commission deem necessary to implement an ethical and trustworthy AI ecosystem based on EU’s fundamental values. Such eco-system will position Europe’s innovative AI businesses, including SMEs, to offer trusted and competitive AI applications. Nonetheless, there are challenges that may affect SMEs ability to innovate, in particular:

• Proliferation of standards: AI needs several standards that are already either fully developed or can be tweaked to serve AI requirements. There is no need to develop standards from the scratch and duplicate work. For example, data quality standards such as the ISO/IEC 25012 “Data quality model” should be assessed and any AI specific requirement should then rely on existing work and not create AI specific models. This would avoid unnecessary costs and complexity. This is  in line with what is stated in the “data economy” chapter of the Rolling Plan for ICT standardisation 2022. The same is true for record management and preservation. It is not appropriate to define specific requirements for artificial intelligence. Rather, requirements should be defined for the proper application of existing standards.
• Records keeping: In view of the fact that AI systems could have an impact on the fundamental rights of individuals, the proposal requires logs to be preserved. Such preservation should be guaranteed until any impacted stakeholder may need to request access to the logs to defend their rights.
• Conformity assessment: It is essential that SMEs are involved in the development of standards used for conformity assessment. SBS would therefore like to stress the need to include in the standardisation request that in developing standards to support conformity assessment processes, 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. 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).

SMEs early involvement in standardisation development is essential to ensure that cost-effective and SME-compliant standards that help their competitiveness in global markets are developed. Accordingly, increased participation of SME experts is needed. The inclusiveness fund, proposed by CEN-CENELEC Standardisation Request Ad-Hoc Group (SRAHG) on AI is a step in the right direction to fund and appoint more SMEs at technical committees. Furthermore, the SBS WG Digitalisation and its liaison with the European DIGITAL SME Alliance Focus Group AI could also be utilised to properly inform and gather feedback from SMEs.