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The European Commission released its AI Continent Action Plan this week. This high-level communication lays down the various initiatives the European Commission is pursuing to support Europe's AI ambitions and AI uptake in the private sector — advanced manufacturing, aerospace, automotive and pharmaceuticals, among others — and the public sector, be it in health care, justice, education or public administration.

But what if the most influential factors were not in the action plan? It builds on five pillars.

Infrastructure. Europe needs to have enough computing capability to sustain its ambitions, so Brussels is financially supporting developments in high-performance computing and gigafactories in the future.

Access to data. Less than 10% of Europe's industrial data is used. The action plan confirms a nonlegislative data union strategyis expected in the third quarter of 2025. This Communication will aim at making more data available to support AI development and cut unnecessary bureaucracy, simplifying how businesses can meet EU data rules, facilitate access and sharing, attract more valuable data, and maintain a certain level of protection when data is transferred internationally.

While the action plan does not specify the channel, the strategy is likely to build on the digital omnibus package planned for fall 2025. Interestingly, the European Commission's approach happens as we still need to see the effects of the Digital Governance Act, the Data Act, and data spaces — three initiatives implemented in the past two years, precisely to facilitate data sharing and re-use across the EU.

Strategy. Boosting homegrown European cloud capacity has been a European ambition since the early 2000s, yet somehow political will never met the technical and market reality. This time around, the Commission wants to triple the EU's data center capacity in the next five to seven years. The Cloud and AI Development Act will shed some light on measures considered.

Skills. An "apply AI strategy" will encourage deployment and adoption across industry and the public sector, with a focus on skills and science, technology, engineering and mathematics programs around Europe. The EU will support AI literacy efforts, in light of AI Act requirements, and facilitate legal migration pathways.

Simplification of rules. In parallel to its AI plans, the European Commission is looking at the digital rulebook, and any overlaps and interplay of rules, in hopes of cutting red tape. In the fall, the upcoming Omnibus simplification package will be proposed on digital policy, including to simplify documentation and notification requirements under the EU General Data Protection Regulation and NIS2 Directive.  

The action plan also alludes to possible changes to the AI Act, yet to be fully implemented and which could still generate up to 60 secondary pieces of legislation by the EU AI Office.

What isn't in the action plan are in fact a lot of important points, not least of which is who will pay for all these initiatives. The action plan mentions both public-private partnerships and European funding programs — largely funded by contributions from member states.  

The outcomes of the action plan will also be vastly influenced by where European leaders stand on three areas that will significantly inform organizations' approach to AI governance:

  • Sovereignty and its operational consequences from data flows to technology sourcing.
  • Coherence of rules and simplification, as EU laws intersectionality has yet to be clarified and untangled.
  • Upskilling professionals to ensure AI governance at-scale can support Europe's ambitions.

Isabelle Roccia, CIPP/E, is the managing director, Europe, for the IAPP.

This article originally appeared in the Europe Data Protection Digest, a free weekly IAPP newsletter. Subscriptions to this and other IAPP newsletters can be found here.