We welcome the chance to contribute to this open consultation on the Draft Regulation for establishing the AI Scientific Panel of Experts. As representatives of the healthcare community, particularly in radiology, we see this as a crucial step toward effective governance and safe integration of AI technologies into specialized domains such as medical imaging.
Article 3: The draft regulation could benefit from clarity regarding the selection process for the call of expression of interest. We recommend ensuring transparency and consistency in this process, particularly in eligibility requirements and evaluation procedures. While national representation is valuable, we suggest placing equal emphasis on sector-specific expertise. In healthcare, and radiology specifically, distinct challenges and applications require specialized knowledge, best addressed by professionals with deep expertise. We also recommend elaborating on the role of the reserve list—its strategic purpose, intended use, and how those on it may eventually be engaged in the panel’s work.
Article 7: The tasks of the AI Scientific Panel as defined seem largely reactive, responding to requests rather than contributing proactively. It could be valuable to explore a more permanent advisory role to ensure continuous integration of scientific expertise, particularly for AI applications in healthcare. Further clarification on the process of requesting recommendations or opinions would provide insight into how sector-specific expertise will be organized, which may benefit from thematic working groups.
Article 12: While we welcome the commitment to post-establishment transparency, it is equally important to ensure transparency in the establishment process itself. Currently, there is no clarity on how the open call for expression of interest will be organized or what selection criteria will be applied. Healthcare professional organizations like ESR possess the networks and knowledge necessary to effectively reach medical professionals. Understanding how the AI Office plans to conduct the call is essential for us to provide constructive feedback to ensure the panel includes diverse expertise, particularly in healthcare and radiology.
We believe these amendments will strengthen the regulation, enhancing its effectiveness in ensuring a competent, well-composed AI Scientific Panel. We welcome the chance to provide feedback and hope similar stakeholder engagement remains core to the AI Act’s governance.
References
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European Society of Radiology (ESR). Guiding AI in Radiology: ESR’s Recommendations for Effective Implementation of the European AI Act. Insights Imaging (under revision).
European Society of Radiology (ESR). What the radiologist should know about artificial intelligence – an ESR white paper. Insights Imaging. 2019 Apr 4;10(1):44. doi: 10.1186/s13244-019-0738-2. PMID: 30949865; PMCID: PMC6449411.
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