The IIF has submitted comments in response to the European Commission’s consultation on “Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector,” published on June 18, 2024. The IIF considers this consultation very timely both in view of the growth in potential applications for artificial intelligence (AI) in the financial sector and in view of the importance of the EU’s AI Act to sectors including the financial sector.

Our comments draw upon member feedback from the 2023 IIF-EY Public Survey Report on AI/ML use in financial services, discussions with our AI/ML Experts Group comprised of senior business representatives across our global membership, and frequent bilateral contacts with our members. Among other items, we highlight existing sectoral and cross-sectoral regulation of AI in finance as well as financial institutions’ existing risk management governance frameworks, systems and controls. At this stage, the IIF does not believe that further technology-specific regulation with respect to AI as a general-purpose technology, or within the financial services industry specifically, is warranted or desirable; rather, we would urge focus on deduplication and welcome some harmonization or clarification on the interplay among existing regulations.