European insurers already deliver a broad range of insurance products and services for AI users and producers. However, if the EU were to make substantial changes to the Product Liability Directive (PLD), it could make it difficult for insurers to continue to insure certain risks.
The Commission should therefore refrain from introducing major changes to the existing framework to enable insurers to keep making accurate risk calculations and cater to constantly evolving market demands and realities.
Moreover, the PLD should remain restricted to personal injury and property damage, as other types of damage and harm are already compensable under existing legislation such as the Environmental Liability Directive and the General Data Protection Regulation respectively.
Furthermore, new rules should only be considered in the case of a clear protection gap, which currently does not exist.
The full response document is available online here.