The undersigned industry associations represent a broad spectrum of companies operating across Europe and beyond, spanning the entire AI value chain. Our members are at the forefront of transformative advances in AI technologies, which generate substantial benefits to the EU’s economy and society.

On 19 November 2025, the European Commission presented its Digital Omnibus on AI, delivering on the objectives of its Communication on a Simpler and Faster Europe to promote “unprecedented simplification measures that aim to radically lighten the regulatory load”. In line with the Letta and Draghi reports, the proposal promotes forward-looking, innovation-driven policies to strengthen the European Union’s competitiveness, reduce regulatory burdens, and uphold its core values. We, the signatories of this joint statement, welcome this initiative and share the Commission’s commitment to a clear, simple and innovation-friendly implementation of the AI Act, as set out in the AI Continent Action Plan and the Apply AI Strategy. The AI Omnibus is an important step in the right direction.

As both co-legislators adopted their respective positions, we call on them to swiftly reach a final agreement, support a highly ambitious text, and ensure that regulatory simplification remains at its core. We welcome the alignment between both the European Parliament and the Member States regarding fixed compliance deadlines for high-risk AI systems, and we fully support the Parliament’s amendment to move Section A of Annex I into Section B in order to streamline overlaps with existing EU sectorial legislation, avoid unnecessary duplication, and support a clear and integrated conformity pathway. These approaches not only uphold the essence of simplification but also preserve high safety standards while improving legal certainty, regulatory efficiency, and predictability for innovation.

However, we strongly encourage policymakers to consider some key targeted adjustments to retain the initial ambition of the simplification agenda, as well as to ensure that the framework is genuinely innovation-friendly and technology-neutral. We urge co-legislators to adopt a pragmatic simplification approach by not only maintaining the European Commission’s proposed grace period for generative AI labelling under Article 50(2), but also extending it to a more realistic period of 12 months. EU negotiators should also extend the grace period to the labelling requirements set out in Article 50(4). Finally, the provision must be extended to cover new systems on the market. The grace period is currently limited to AI systems already on the market before 2 August 2026 and therefore does not provide legal certainty for systems placed on the market after that date. Without such adjustments, these unclear obligations, pending the development of a Code of Practice and guidance from the AI Office, risk creating inconsistency, legal uncertainty, and delays to product releases (and thus AI innovation in Europe).

Furthermore, we fully support both the principle and the importance of the proposals for the prohibition of AI systems used for “nudification”, non-consensual intimate imagery (NCII), and child sexual abuse material (CSAM). When addressing this issue, policymakers should ensure consistency with the European Commission’s guidelines on prohibited practices under the AI Act.

Finally, we recommend returning to the Commission’s proposal to allow AI systems not classified as high-risk to be exempt from registration in the EU database. This approach would streamline compliance and reduce disproportionate burdens on companies and enforcement authorities, while preserving the risk-based approach of the EU AI Act.

These simplification efforts are essential to ensuring that the implementation of the AI Act is smooth, predictable, and conducive to innovation, thereby enabling Europe to strengthen its position as a global leader in AI and to pursue a safe and effective AI-first approach.

We look forward to continuing to work constructively with EU policymakers in support of these shared objectives.

Your sincerely,

The undersigned:
ACT – The App Association
American Chamber of Commerce to the European Union (AmCham EU)
Association des Services Internet Communautaires (ASIC)
Association of the Internet Industry (ECO)
Business Software Alliance
Chamber of Progress
Computer & Communications Industry Association (CCIA Europe)
Developers Alliance
DOT Europe
European Association of Internet Services Providers (EuroISPA)
European Automotive Manufacturers’ Association (ACEA)
Federation of European Data and Marketing (FEDMA)
German Association for the Digital Economy (BVDW)
ITI, Information Technology Industry Council
Union of Entrepreneurs and Employers (ZPP)

Read the full joint statement here:

EuroISPA, CISPE and Digital SME Alliance’s reaction to current legislative developments in Italy
on the extension of a copyright levy on private copies stored in cloud

The organisations EuroISPA, CISPE and the European DIGITAL SME Alliance would like to share their concern on the worrying developments in Italy on the introduction of a recurring private copy levy specifically targeting cloud storage services, based on Article 5 on Exceptions and Limitations of Directive 2001/29/EC on the harmonisation of certain aspects of copyright and related rights in the information society (InfoSoc Directive).  

Context: 

A new Italian decree, whose final version has been signed by Italy’s Minister of Culture on 23 February 2026, introduces a monthly levy on “cloud memory or cloud storage space”, calculated per GB and per user (with a monthly cap per user), as well as new reporting and administrative obligations for providers, shifting the system from a one-off levy on devices and supports to a recurring charge on the mere availability of cloud storage. 

The decree is currently awaiting its publication in the Official Journal of Italy. 

Risks: 

The signatories are concerned about the repercussions that this measure might have at European level, as well as potential consequences if applied to any remote storage accessible to nationals, including a presumption of some private use in B2B cases. 

In particular, this approach may: 

1. Create fragmentation within the EU Single Market: Should other Member States adopt similar measures, this would risk introducing divergent national regimes, thereby undermining the integrity and proper functioning of the EU Single Market; 

2. Undermine EU and national digitalisation objectives: Such measures would run counter to key EU and national policy goals aimed at accelerating digital transformation, including the Digital Decade target of achieving 75% cloud uptake and the AI Continent Action Plan objective of tripling data centre capacity; 

3. Conflict with the EU’s simplification and competitiveness agenda: The proposed system risks introducing significant administrative and financial burdens for companies operating in Italy, including innovative SMEs, thereby undermining efforts to streamline regulatory frameworks and enhance Europe’s competitiveness; 

4. Level playing field concerns: The current framework may also create competitive imbalances, making it easy to impose levies on operators with an Italian operational base, while their international competitors are much more likely to avoid them due to legal complexity and the regulator’s limited monitoring capacity; 

5. Lack sufficient legal justification: As further detailed below, the introduction of such measures appears unsupported by evidence of concrete harm. 

The 2022 Court of Justice of the European Union (CJEU) judgment on Austro-Mechana v Strato¹ expressly limited any “fair compensation” under Article 5(2)(b) of Directive 2001/29/EC to be strictly linked to the actual harm suffered by rightsholders as a result of private copying. In particular, the Court reiterated that such compensation must be demonstrably connected to the harm caused; however, the Italian decree does not appear to provide evidence establishing either the existence or the extent of such harm. 

In light of this development, EuroISPA, CISPE and Digital SME Alliance call for: 

1. An urgent discussion between the Commission and Italy to ascertain the legality of the Decree and mitigate its imminent negative effects on the Single Market; 

2. The Commission to urgently initiate a review of the InfoSoc Directive with the view of harmonising copyright levies at European level before every Member States adopts their own different rules, leading to a serious fragmentation of the single market and jeopardising the EU’s digitalisation, simplification and competitiveness objectives. 

Signatories: 

• EuroISPA (European Internet Services Providers Association) 

Established in 1997, EuroISPA is the world’s largest association of Internet Services Providers Associations, representing over 3,300 Internet Service Providers (ISPs) across the EU and EFTA countries. EuroISPA is recognised as the voice of the EU ISP industry, reflecting the views of ISPs of all sizes from across its member base. 

• CISPE (Cloud Infrastructure Services Providers in Europe) 

CISPE is the largest and most representative organisation for European cloud infrastructure providers, with a sovereign governance protecting it against foreign influence. Since 2016, CISPE has been working with EU institutions to support reasonable and ambitious cloud policies that strengthen Europe’s digital competitiveness, sovereignty and sustainability. Besides policy work, CISPE also develops concrete tools for the industry to comply with legislation such as the GDPR and the Data Act and issues warnings against developments around Europe that could threaten the health of the European cloud ecosystem. 

• European DIGITAL SME Alliance 

The European DIGITAL SME Alliance is the largest network of ICT small and medium enterprises in Europe, representing more than 45,000 companies. DIGITAL SME is the joint effort of 30 national and regional SME associations from EU member states and neighbouring countries to put digital SMEs at the centre of the EU agenda. 

Read the full joint statement here: