Impact on SMEs and non-EU businesses
We welcome the Commission's specific consideration of the impact of the proposed regulatory framework on SMEs, which, as discussed above, could arise at several stages, and the proposal that "in order to limit the burden on SMEs, some support structure might be envisaged including through the Digital Innovation Hubs."
Since the Commission proposes that these rules apply to everyone providing AI solutions in the EU market, we would also urge the Commission to consider how the framework and enabling measures would affect differentially EU and non-EU businesses, for instance in terms of access to testing centres and support from Digital Innovation Hubs.
We welcome the emphasis placed on developing AI and digital skills in SMEs within the EU SME Strategy. The Scottish Government has been participating in the OECD's Digital for SMEs Global Initiative, which aims to promote knowledge sharing and learning on how to enable all SMEs to make the most of the digital shift. This initiative places specific emphasis on the diverse opportunities and needs of the large "missing middle" of SMEs and on their role for an effective, inclusive and sustainable digital transition, and includes looking at the role of AI for SMEs. We will continue to engage with the OECD on three pillars that underpin the initiative: analytical research, sharing SME experiences, and network and policy dialogue.