AI Chamber Issues New Open Letter Warning Against Overregulation in EU AI Code

Warsaw, 3 April 2025 – Leading organizations from the AI, startup, and SME sectors across Central and Eastern Europe have signed a new open letter voicing deep concerns over the Third Draft of the General Purpose AI (GPAI) Code of Practice (CoP). The letter, coordinated by AI Chamber, urges the European Commission to revise the Code before it is finalized, warning that, in its current form, it threatens to stifle innovation and impose disproportionate burdens on smaller AI developers.

The GPAI Code aims to serve as a key framework for general-purpose AI providers to demonstrate compliance with the AI Act, which comes into force in August 2025. However, as the letter highlights, the current draft risks creating a “bureaucratic monster” — adding obligations beyond the AI Act and failing to reflect the realities of small and medium-sized AI businesses.

“The business impact of these requirements cannot be understated,” says Tomasz Snażyk, CEO of AI Chamber. “Startups and SMEs simply don’t have the resources to meet these overly complex requirements. If we want Europe to remain globally competitive, we must stop overregulating innovation out of existence.”

Key Concerns Raised in the Letter:

• Overcomplexity and vague provisions, such as obligations to “make reasonable efforts” to ensure dataset compliance.

• Unclear adoption expectations – whether organizations must commit to the entire Code or only parts of it.

• Copyright ambiguity, with requirements that go beyond existing EU frameworks.

• Excessive documentation and audit demands that disproportionately affect SMEs.

• Language accessibility, excluding many developers due to a lack of localized versions.

• Open-source model risks, where a lack of clarity may create regulatory loopholes or hinder open development.

While the third draft introduces improvements—such as streamlining and the introduction of a Model Documentation Form—the signatories stress that the framework still heavily favors BigTech players and neglects the resource constraints of smaller developers. Without significant revisions, the Code could inadvertently become the de facto market standard, impacting non-signatories and setting unrealistic compliance benchmarks.

“The GPAI Code of Practice should be an enabler of growth, not a new layer of red tape,” emphasizes Snażyk. “We need voluntary frameworks that support the full AI ecosystem—not just the largest players with dedicated legal teams.”

Read the Full Open Letter

📄 Download the full letter here

Interested in Supporting the Letter?

If your organization would like to join the list of signatories, please contact us at contact@aichamber.eu.