Joint Industry Statement on the Upcoming EDPB Opinion on Data Processing in the Context of AI Model Training

As part of our commitment to ensuring startups can thrive in Europe’s evolving tech landscape, Allied for Startups has co-signed a joint industry statement addressing the upcoming European Data Protection Board (EDPB) Opinion on data processing for AI model training.

While we appreciate the opportunity for input, the complexity of this issue may require more comprehensive and iterative guidance than a fast-track Opinion can provide. A more detailed, inclusive approach would better support Europe’s ambition to lead in trustworthy AI.

The EDPB’s guidance will play a pivotal role in shaping how Europe balances privacy with innovation. As noted in the Draghi report on European Competitiveness, regulatory uncertainty risks slowing AI development and undermining Europe’s leadership. The upcoming Opinion should aim to clarify rules and reduce barriers for AI that aligns with European values.

Key Considerations for the EDPB Opinion

To ensure that the regulatory framework supports responsible AI development while upholding privacy rights, we encourage the EDPB to:

1. Clearly Define Scope
   Limit the Opinion’s focus to the processing of personal data for training and developing generative AI models, providing clarity to organizations navigating compliance.

2. Apply Uniformly Across Controllers
   Ensure equal application of principles to all data controllers involved in AI model training—regardless of size or sector—consistent with the GDPR’s foundational principles.

3. Maintain a Technology-Neutral, Principles-Based Approach
   Avoid prescriptive technical mandates. Instead, preserve the GDPR’s flexible, principles-based approach, which allows controllers to adapt to fast-moving AI developments.

4. Facilitate Responsible Access to Data
   Access to sufficient, high-quality data is not only crucial for innovation, but also for mitigating bias and enhancing the representativeness of AI systems. A regulatory approach that avoids imposing unjustified barriers to data access is key to ensuring the development of AI that reflects and upholds European values.

Along with other co-signatories, we look forward to contributing to constructive dialogue during the upcoming stakeholder event. We commend the EDPB for opening a formal channel for feedback and encourage the continuation of this inclusive approach moving forward.

We remain committed to collaborating on a shared vision of AI that thrives within Europe’s legal and ethical framework—ensuring innovation, safeguarding rights, and promoting European leadership in trustworthy AI.

Signatories

• Asociación Española de la Economía Digital (Adigital) – 367588046372-04

• Afnum – 832852453029-02

• Allied for Startups – 634665118544-37

• Association des Services Internet Communautaires (ASIC) – W751242219

• Association of the Internet Industry (ECO) – 483354220663-40

• Computer & Communications Industry Association (CCIA Europe) – 281864052407-46

• DOT Europe – 53905947933-43

• EuroISPA – 54437813115-56

• Federation of European Data and Marketing (FEDMA) – 39300567160-02

• ITI – Information Technology Industry Council – 061601915428-87

• NL Digital – 513647192411-18

• Slovak Alliance for Innovation Economy (Sapie) – 793779648066-85

• Startups Cyprus

• Startups Hungary – 086426750559-91

• Technology Ireland – 479468313744-50