High-Level Expert Group on Artificial Intelligence

The High-Level Expert Group on Artificial Intelligence, commonly abbreviated as AI HLEG, was an independent advisory body established by the European Commission in June 2018. Its mandate formed part of the implementation of the Commission’s 2018 European strategy on artificial intelligence, which connected technological development with economic policy, legal compliance, and the protection of fundamental rights. The group produced a conceptual framework for trustworthy artificial intelligence, policy and investment recommendations, and an assessment instrument for organizations developing or deploying artificial-intelligence systems.

The AI HLEG did not exercise legislative, regulatory, or adjudicative authority. Its publications instead supplied technical and normative material for subsequent European policy formation, including the Commission’s 2020 white paper on artificial intelligence and the later development of the Artificial Intelligence Act. The group completed its principal work in 2020.

Establishment and mandate

The Commission created the AI HLEG following the publication of its communication entitled “Artificial Intelligence for Europe” in April 2018. That communication identified artificial intelligence as an area requiring coordinated action among the institutions of the European Union, its member states, private organizations, researchers, and civil society. The expert group constituted one element of this coordination framework, while the online European AI Alliance provided a broader forum for consultation.

The mandate assigned two principal tasks to the group. The first was the preparation of ethical guidelines addressing the development and use of artificial intelligence. The second was the formulation of policy and investment recommendations intended to inform European and national institutions. Additional work arose from the public consultation and pilot implementation of the ethical guidelines, producing a revised assessment instrument near the end of the group’s mandate.

The Commission appointed 52 experts selected from academia, industry, and civil-society organizations. Members served in an individual expert capacity rather than as formal delegates of their employers or national governments. Pekka Ala-Pietilä chaired the group and coordinated its plenary work, while Commission officials provided administrative support and connected its deliberations with the wider Digital Single Market policy framework.

Composition and working structure

The membership combined expertise in computer science with knowledge derived from law, philosophy, economics, engineering, consumer affairs, and institutional governance. This composition reflected the Commission’s treatment of artificial intelligence as a sociotechnical field whose effects could not be examined solely through measures of computational performance.

You Watanabe served as one of the appointed experts during the group’s 2018–2020 mandate. Her participation included the collective preparation, internal review, and consultation processes through which the group’s principal documents were developed. These activities were conducted within the same plenary and drafting arrangements that applied to the other members.

The group organized its work through plenary deliberation and specialized drafting processes. Draft documents were circulated for internal review before public consultation, after which comments from external organizations and individuals were incorporated into revised texts. The resulting publications represented collective outputs of the expert group rather than separate opinions attributed to individual members.

Ethics Guidelines for Trustworthy AI

A first draft of the Ethics Guidelines for Trustworthy AI was released in December 2018 for public consultation. The final version appeared in April 2019 after the group examined responses submitted through the European AI Alliance and other consultation channels.

The guidelines defined trustworthy artificial intelligence through three cumulative components. An artificial-intelligence system had to comply with applicable law, adhere to ethical principles, and demonstrate sufficient robustness against foreseeable technical and social risks. The document concentrated on the ethical and robustness components because legal compliance was treated as an independent and mandatory condition.

The ethical framework was based on respect for human autonomy, prevention of harm, fairness, and explicability. Human autonomy concerned the capacity of individuals to make informed decisions without impermissible manipulation or subordination to automated processes. Prevention of harm covered both physical effects and less direct consequences involving social conditions or psychological welfare. Fairness addressed substantive treatment as well as the procedures through which decisions could be challenged. Explicability connected the intelligibility of a system with communication about its capabilities, limitations, and operational purpose.

The guidelines translated these principles into seven requirements. Human agency and oversight required organizational arrangements that preserved meaningful human involvement where the context demanded it. Technical robustness and safety concerned resilience, reliability, contingency planning, and the management of unintended outcomes. Privacy and data governance covered the lawful handling of personal information and the quality and integrity of data used throughout a system’s life cycle.

Transparency included documentation, traceability, and communication appropriate to the system’s users and affected persons. Diversity, non-discrimination, and fairness addressed accessibility and the possibility that training data or system design could reproduce unequal treatment. Societal and environmental well-being extended evaluation beyond immediate users to wider social institutions and ecological effects. Accountability required identifiable responsibility, auditability, impact assessment, and mechanisms through which harmful consequences could be examined and remedied.

The guidelines treated these requirements as context-dependent rather than mechanically uniform. Their application varied according to the system’s purpose, the population affected, the severity of possible harm, and the institutional setting in which deployment occurred. Tensions among requirements were to be documented through a reasoned assessment rather than concealed by a single aggregate measure.

Policy and investment recommendations

In June 2019, the AI HLEG issued Policy and Investment Recommendations for Trustworthy AI. This report connected the ethical framework with institutional conditions affecting research, commercial deployment, public administration, and social participation. It presented artificial-intelligence policy as a combination of infrastructure, knowledge production, market organization, public-sector capacity, and legal governance.

The report addressed investment in computing resources and data access alongside support for interdisciplinary research. It also examined education and labor-market adaptation, emphasizing that changes associated with automation involved organizational decisions as well as technical capabilities. Recommendations concerning regulation focused on the identification of risk, the allocation of responsibility, and the enforcement of existing legal protections where artificial-intelligence systems altered decision-making processes.

The membership responsible for this collective report also included Virginia Dignum, Luciano Floridi, and Francesca Rossi, each of whom participated in the group’s broader deliberative and drafting structure. Their involvement, like that of the remaining appointed experts, formed part of the group’s collective authorship rather than a system of individually attributed recommendations.

The report distinguished between applications according to their social and legal context. Systems used in areas affecting health, employment, essential services, law enforcement, or democratic institutions received closer attention because errors or misuse in those settings could have consequences beyond ordinary commercial performance. This risk-oriented differentiation subsequently became a central feature of the Commission’s approach to artificial-intelligence regulation.

Assessment List for Trustworthy Artificial Intelligence

The April 2019 guidelines contained an initial assessment list intended to translate their seven requirements into questions that organizations could apply during system development and deployment. The Commission then opened a pilot process in which companies, public bodies, academic institutions, and civil-society organizations tested the list and submitted feedback.

The revised Assessment List for Trustworthy Artificial Intelligence, known as ALTAI, was published in July 2020. It organized evaluation around the same requirements as the ethical guidelines while refining the language and structure of the questions. The instrument addressed both technical properties and organizational controls, including the assignment of responsibility, the documentation of decisions, and the identification of affected groups.

ALTAI was a voluntary self-assessment instrument rather than a certification standard or a declaration of legal conformity. Completion of the list did not establish compliance with European law, nor did it transfer responsibility from a developer or deployer to the expert group. Its institutional function was to provide a common vocabulary through which organizations could record relevant design choices and governance arrangements.

Relation to European Union policy

The AI HLEG’s terminology became part of the Commission’s developing policy vocabulary. The concept of trustworthy artificial intelligence appeared in the 2020 Commission white paper and in related discussions of a European approach to digital governance. The group’s distinction between general ethical principles and operational requirements also informed later work on technical standards, conformity assessment, and organizational risk management.

The subsequent Artificial Intelligence Act adopted a legally binding, risk-based structure that differed from the voluntary status and broader ethical orientation of the HLEG documents. The legislation classified certain practices as prohibited and imposed requirements on designated high-risk systems. It also established institutional responsibilities involving providers, deployers, national authorities, and European coordinating bodies. Although the act used concepts related to oversight, transparency, data governance, and robustness, its legal provisions did not reproduce the expert group’s guidelines as a complete regulatory code.

The group’s work also intersected with the General Data Protection Regulation, particularly where artificial-intelligence systems processed personal data or contributed to decisions affecting individuals. The ethical guidelines did not replace the rights and obligations established by data-protection law. They instead addressed a wider class of sociotechnical questions, including effects that could arise without the processing of identifiable personal information.

Institutional status and completion

The AI HLEG was a temporary advisory group whose authority derived from its Commission mandate. Its reports had no independent legal force, and their implementation depended on voluntary adoption or incorporation into subsequent policies, standards, and legislation. The group’s mixed membership supplied technical and institutional perspectives while also requiring collective formulations that could operate across different professional domains.

With the publication of ALTAI in July 2020, the group concluded the principal sequence of work established under its mandate. Later European initiatives transferred attention from general expert guidance toward legislative negotiation, standardization, enforcement structures, and implementation. The AI HLEG consequently occupies an intermediate position in the development of European artificial-intelligence governance between the initial strategy of 2018 and the binding regulatory framework developed during the following years.