Artificial Intelligence Act

Open Loop – EU AI Act program


On June 10th 2022, we launched the Open Loop program focused on the EU AI Act proposed by the European Commission on April 21st 2021. The program involves over 50 participating companies that tested key requirements of the proposal in order to make them clearer, more technically feasible, and more effective.

The policy prototyping program is structured into three distinct, yet intertwined parts, each tackling specific themes and sections of the EU proposal, namely:

The policy prototyping program consists of:

  1. An inception phase, with 62 participants from over 50 AI startups and companies operating in the EU sharing their feedback on key articles of the EU proposal, commenting on their clarity, feasibility and cost-effectiveness. Inputs were gathered via the Open Loop Forum, an online platform for discussion around a variety of topics divided into 7 activities:


  2. A deep dive phase, where selected companies tested the implementation of some of the requirements listed in articles 9, 13, 14 and Annex IV of the AI Act, with a focus on the transparency measures to ensure the interpretability of the output and on the requirement for providers of high-risk AI systems to have a risk management system in place.  As part of this phase, the program also tested the provision on transparency obligations for AI systems interacting with natural persons (article 52), the section on regulatory sandboxes (article 53) and the taxonomy of AI actors (article 3) presented in the AI Act.

  3. A co-creation phase, where participating companies, observers and partners from industry, governmental entities, regulatory authorities, academia, and other non-governmental organizations convene in workshops and policy jams to discuss the results of the first phases, and contribute to the design of alternative taxonomies.

The outcomes of this policy prototype will result in a series of reports with actionable and evidence-based policy recommendations.

The program contributes to:

  • The improvement and refinement of key concepts, provisions and processes outlined in the AI Act, in particular those related to its technical and procedural requirements.
  • Making the AI Act clearer, more operational and technically feasible.
  • The creation of consensus-based standards and guidelines, thanks to the development of common technical specifications and codes of conduct for compliance with the AI Act technical requirements.
  • Informing in a timely manner the negotiations and final drafting of the AI Act through evidence-based inputs.

Through a series of surveys, moderated discussions and interactive workshops, the program deploys qualitative and quantitative methods and involves industry partners, EU Institutions, governmental entities, regulatory authorities, academics, and other non-governmental organizations.


The report presents the findings and recommendations of the first part of the Open Loop’s policy prototyping program on the European Artificial Intelligence Act (AIA), which was rolled out in Europe from June 2022 to July 2022, in partnership with Estonia’s Ministries of Economic Affairs and Communications and Justice, and Malta’s Digital Innovation Authority (MDIA).

We enlisted 53 AI companies to participate in the Open Loop Forum (OLF), a dedicated online platform where they met to discuss topics and complete several research-related tasks.

The overall picture is that most of the AIA provisions addressed in this program are clear, feasible and may contribute to the overall goal of creating trustworthy AI. However, there are several areas in the AI Act where there is room for improvement, and some provisions that might even undermine another goal of the legislator: the uptake of AI in Europe.


For this Open Loop program, we are partnering with the Malta Digital Innovation Authority and the Government of Estonia, while being supported by Considerati and Hyve Innovate.

Malta Digital Innovation Authority

Republic of Estonia Government



Participating companies



Ask Mona



Credo ai




Enzai Technologies Limited

evo pricing



Future Intelligence

Gossik AG



Irida Labs

Keepler Data Tech




M3i Industry-in-Clinic-Platform






Polaris Engineering

Qubit Ventures





Tgs Baltic

The Newsroom

The VR Hive


Travers Smith

Vedrai SPA




Vytautas Magnus University



YData Labs Inc


ML cube

Armilla AI


Members of European Parliament

  • Eva Maydell
    ITRE Rapporteur of the AI Act, (BG, EPP)

  • Ivan Štefanec
    President of SME Europe (SK, EPP)

International Institutions / Governmental Authorities

  • Karine Perset,
    Head of AI Unit and OECD.AI, Organisation for Economic Co-operation and Development (OECD)

  • Andras Hlacs,
    AI Policy Analyst, OECD.AI, Organisation for Economic Co-operation and Development (OECD)

  • Richard Nevinson,
    Head of Digital Economy, Information Commissioner’s Office (ICO)

  • Henrik Trasberg,
    Legal Advisor on AI and New Technologies, Ministry of Justice of Estonia

  • Ott Velsberg,
    Government Chief Data Officer, Estonian Ministry of Economic Affairs and Communications

  • Kenneth Brincat, CEO,
    Malta Digital Innovation Authority (MT)

  • Alessandro Fusacchia,
    Member of the Italian Parliament, Coordinator of Parliamentary Intergroup on AI

  • Luca Carabetta,
    Member of the Italian Parliament

  • Zümrüt Müftüoğlu
    Expert – Digital Transformation Office of the Presidency of the Republic of Türkiye

  • Işıl Selen Denemeç
    Head of Legal Department – Digital Transformation Office of the Presidency of the Republic of Türkiye

Academia / Think Tanks

  • Andrea Bertolini,
    EURA Centre, Scuola Superiore Sant’Anna Pisa

  • Eduard Fosch,
    Leiden University

  • Evert Stamhuis,
    DIGOV Centre Rotterdam University

  • Fabiana di Porto,
    University of Salento and LUISS University

  • Giovanni Sartor,
    University of Bologna and European University Institute

  • Johann Laux,
    Oxford Internet Institute

  • Klaus Heine,
    Professor, DIGOV Centre Rotterdam University

  • Virginia Dignum,
    Umeå University

  • Nicolaos Voros,
    University of the Peloponnese

  • Joshua Ellul,
    University of Malta and Former chairman, Malta Digital Innovation Authority

  • David Osimo,
    Lisbon Council

  • Risto Uuk,
    Future of Life Institute

Industry Associations



Infobalt Lietuva

Civil Society



privacy network

The Future Society