SIIA Submits Comments on EU Digital Omnibus to Clarify AI Act’s Application to EdTech

The Software & Information Industry Association (SIIA) submitted comments to the European Commission's Directorate-General for Communications Networks, Content and Technology in response to its Call for Evidence: Digital Omnibus (Digital Package on Simplification). SIIA's submission focuses on ensuring a predictable and effective application of the EU Artificial Intelligence Act (AI Act), particularly in the field of educational technology.

SIIA supports the AI Act's goal of protecting citizens while fostering innovation but raises concerns that classifying "education and vocational training" systems as high risk could hinder the European EdTech ecosystem-composed largely of small companies serving millions of learners and educators. SIIA recommends that the Commission clarify the distinction between AI-assisted learning tools, which support educators, and AI-determined systems, which make autonomous decisions about learning outcomes. Clearer guidelines, SIIA argues, will help advance responsible AI adoption while reducing regulatory uncertainty and administrative burden across the education sector.