On February 19, 2020, the European Commission ("EC")
presented its long-awaited proposal for comprehensive regulation of
artificial intelligence ("AI") at European Union
("EU") level: the "White Paper on Artificial
Intelligence – A European approach to excellence and
trust" ("White Paper").1 In an op-ed
published on the same day, the president of the EC, Ursula von der
Leyen, wrote that the EC would not leave digital transformation to
chance and that the EU's new digital strategy could be summed
up with the phrase "tech sovereignty."2
As anticipated in our
2019 Artificial Intelligence and Automated Systems Annual Legal
Review, the White Paper favors a risk-based approach with
sector and application-specific risk assessments and requirements,
rather than blanket sectoral requirements or bans. Together with
the White Paper, the EC released a series of accompanying
documents, including a "European strategy for data"
("Data Strategy")3 and a "Report on the
safety and
