The Standards Development Representation Gap

Technical standards for AI governance are developed through meticulous, lengthy processes that favor large multinational companies with dedicated standards teams, while NGOs, SMEs, academia, and citizen interests struggle to maintain effective participation.

The concern compounds when European Standards Organizations (CEN/CENELEC) adopt international ISO/IEC standards wholesale, developed by global membership where European civil society voices are further diluted. Since harmonized standards essentially enter EU law and determine how consumer protections are implemented in practice, this representation gap creates a democratic legitimacy challenge.

The problem is structural: effective standards participation requires sustained expert engagement over multi-year timelines, which only well-resourced organizations can afford.

Related: 05-atom—fundamental-rights-direct-effect-problem, 05-atom—horizontal-vertical-regulation-tension, 05-atom—meta-learning-governance