Feedback on Consumer Protection lawmaking submitted to European Commission's Directorate-General for Justice and Consumers on 24 Oct 2025
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Cite as: Harshvardhan J. Pandit, "AIAL's Comments to the European Commission's Digital Fairness Act Consultation" AI Accountability Lab (AIAL). https://aial.ie/research/policy/consultation-2025-EU-Digital-Fairness-Act DOI: 10.5281/zenodo.17429524
This document represents the answers prepared by the team at AI Accountability Lab (AIAL) for the European Commission’s Digital Fairness Act Consultation, conducted by the European Commission as part of the lawmaking process. The consultation was open from 17th July until 24th October 2025, during which the AIAL team submitted its response.
The Digital Fairness Act represents a landmark regulation as it directly addresses key misgivings about the experiences of consumers online. The comments provided by the AIAL are based on its findings established through research, analysis of the current realities, and a careful assessment of practical feasibility. We hope the Commission will find our recommendations useful and pragmatic, and are available to engage further on these as well as other measures to support the EU’s implementation of regulations as instruments for upholding our fundamental rights.
In light of the current discussions surrounding simplification, we request the Commission to investigate measures that reduce the effort of enforcement by supporting organisations with their compliance instead of focusing on reduction or dilution of regulations. For the Digital Fairness Act, this means ensuring a high-degree of consumer protection, as required by the Charter of Fundamental Rights, is provided through the regulation with simplification via supporting resources and procedures rather than dilution. Indeed, we feel that the EU can and should utilise its highly valued rights and freedoms as the very measures for measuring competitiveness and innovation, rather than focusing only on the artificially amalgamated metrics regarding its economy. We reiterate that a healthy and competitive EU is one where the competition comes from a high degree of assurance and accountability, and not where such measures can be easily sidelined for economic reasons.