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EPRS BRI(2023)739342 EN · Table (p.3)

From EPRS_BRI(2023)739342_EN.pdf · page 3

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01
Artificial intelligence liability directive
claim (independent of fault), or on a claim against the producer of a defective product (victims
must prove that the product was defective and the causal link between that defect and the damage).
Concerns regarding existing liability rules
The 2018 evaluation report of the PLD identified several shortcomings in relation to digital
technologies in general and to AI in particular.
First, the European Commission found that while digital content, software and data play a crucial
role in the functioning of many new products, it remains unclear to what extent such intangible
elements can be classified as products under the PLD. This triggers legal uncertainty regarding how
injured parties can be compensated for damage caused by software, including software updates,
and who will be liable for such damage. Second, the Commission's investigations showed that new
technologies introduce new risks, such as openness to datainputs that affect safety or
cybersecurity risks, while the PLD provides for compensation only for physical or material damage.
Third, the specific characteristics of AI (e.g. opacity/lack oftransparency, explainability,
autonomous behaviour, continuous adaptation, limited predictability) make it particularly difficult
to meet the burden of proof for a successful claim. Under current liability rules, in order to claim
compensation for damages, victims usually have to prove the existence of damage, a fault of the
liable person, and a causality between that fault and the damage or prove the damage, the defect
and the causal link between the two. However, AI systems have characteristics that make it
excessively difficult or even impossible for victims to identify and prove the fault of a potentially
liable person or a defect and the causal link between that fault/defect and the damage suffered, and
therefore to obtain compensation. 7
As a result, there is a risk that national courts will diverge in their approaches, which could lead to
further fragmentation of liability rules for damage caused by AI across the EU. The Commission's
impact assessment warns of a risk of legal fragmentation, with judges having to interpret general
rules that were not designed with AI in mind to decide liability claims.8 Given that the law applicable
to a liability claim in a cross-border context is by default the law of the country in which the damage
occurs, different liability regimes and burden of proof rules could be applied to the same kind of AI
product or service deployed in several Member States although they cause the same kind of
damage. Therefore, businesses face legal uncertainty due to outdated and unclear EU and national
liability rules, and victims of harm caused by AI products experience difficulty in obtaining
compensation in the EU.
The Commission concludes that this compensation gap could undermine citizens' trust in AI, as
well as the ability of the legal and judicial system to ensure fair and equitable results in claims
involving AI systems.9
Reforming the EU liability framework applicable to AI
The ongoing reform of the EU liability framework applicable to AI is twofold.
The Commission proposed to undertake a review of the PLD10 to adapt it to the digital age and
preserve its technology-neutral nature and coverage. The proposal tabled in September 2022 aims
to modernise the existing rules on the strict liability of manufacturers for defective products
(from smart technology to pharmaceuticals) and ensure that victims can get fair compensation
when defective products, including digital and refurbished products, cause harm. It also helps
victims of damage caused by AI-enabled products to make a more effective compensation claim
against the producer. As such, the PLD review concerns the adaptation of the producers' strict
liability regime for defective products to allow for compensation for damages without the need
to prove a fault. 11
In parallel, the European Commission has unveiled a proposal for an AI liability directive meant to
tackle consumers' liability claims for damage caused by AI-enabled products and services. The
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EPRS_BRI(2023)739342_EN.pdf
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pdfs_from_pdf_links
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pdf
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camelot_stream
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3