Policy prototyping 2025: oproep voor deelnemers - Knowledge Centre Data & Society

The Knowledge Centre Data & Society (KCDS) is launching a new policy prototyping project which will take a closer look at the minimum requirements in contracts between providers of high-risk AI systems and their suppliers in the AI Act (“AIA”).

We are looking for (i) AI providers and suppliers in the AI value chain, and; (ii) legal experts who could both contribute to the creation of prototype contractual clauses.

Policy prototyping refers to a novel way of rulemaking, comparable to product or beta testing. As opposed to traditional policymaking, where all kinds of stakeholders ‘only’ discuss rules before they enter into force, policy prototyping includes a field-testing phase of the new draft rules before finalising and fixating them. Read more about policy prototyping here.

We previously organised policy prototyping projects in 2023 and 2024, focusing on transparency requirements in the AI Act (arts. 13 and 50 AIA) and human oversight requirements in the AI Act (art. 14 AIA). The results and reports are available at our website.

Policy Prototyping 2025

Our next project will focus on the EU AI Act's obligation for high-risk AI providers and their suppliers to include clauses in their mutual contracts regarding e.g. the necessary information and technical capabilities to support the provider’s compliance with the AI Act. More precisely, it concerns the obligation to:

“specify by written agreement the necessary information, capabilities, technical access and other assistance based on the generally acknowledged state of the art to enable the provider of the high-risk AI system to fully comply with the obligations set out in the AI Act.”

In the course of this project, we aim to:

Examine and assess the requirements for contractual clauses between providers of high-risk AI systems and their third-party suppliers, as well as what these clauses should specify.
Create prototype contractual clauses (and related documentation, if needed) which fulfill the AI Act’s requirements.
Gather feedback on these contractual requirements and identify best practices for their fulfillment.

*Miniature figurines of men and women gathered around a table and flip charts in a modern meeting room, occupied with creating a policy prototype, digital art. AI-generated with DALL-E*

Call for participants

To do this, we plan to organise a co-creation workshop in the fall of 2025. This workshop will have several objectives which we will communicate to the participants.

The Knowledge Centre is looking for:

1) AI providers and suppliers of AI providers

Companies developing AI systems;
Companies supplying AI providers with e.g. tools, services, components, AI systems, data or processes;
Deployers of AI systems, providing data or other services to companies developing AI systems on their behalf.
Function: Use case providers and sounding board

Participating providers and suppliers will be able to have their business serve as a use case for the prototyping project. Concretely, their high-risk AI system, or the tools, services or components they supply will be used as the basis for prototype contractual clauses which comply with the AI Act requirements. Suppliers and providers can then give feedback on whether these clauses are well suited for their use. Finally, suppliers and providers can give feedback on the legal requirements in the AI Act. The Knowledge Centre will use the aggregated feedback to provide advice and insights regarding the AI Act to policymakers and other stakeholders.

The estimated time investment for use case providers is one and a half working days (a one-day workshop and up to half a day to provide input on the prototypes after the workshop).

2) Legal/contract drafting experts

Experts with (practical) experience and expertise in drafting IT contracts (ideally involving the development of AI systems or the supply of related services).
Function: co-create and develop prototype contractual clauses (and related documentation, if needed).

Experts will help shape prototypes of the contractual clauses. They can also provide feedback on the AI Act's requirements. In the project they will have the opportunity to engage with the involved providers and suppliers, and improve their proficiency in drafting clauses to comply with the new AI Act requirements.

The estimated time investment for experts is two working days (one workshop day and one day to complete the prototypes).