AI Continent Action Plan

The European Commission’s AI Office (the overarching body overseeing enforcement of the EU AI Act) published its AI Continent Action Plan on April 9, 2025 (“Plan”). In this Plan, the European Commission (“EC”) puts forward how it aims to be at the forefront of AI regulation whilst encouraging AI innovation to turn the EU into a "leading AI continent."

The Plan opens by emphasizing the EC’s view that it is important for the EU to maintain its own distinctive approach to AI regulation which capitalizes on its strengths. Firstly, the EU as a large single market, means it is capable of setting one set of safety rules to be adopted throughout the region; secondly, the EU should make the most of its high-quality research from the pool of talent at its disposal; thirdly, the EU is home to a thriving start-up scene totaling up to 6,800 AI start-ups with much industrial know-how and expertise; and finally, the EU has immense computational power to be supported with further investment. The EC goes on to say that for the EU to become an "AI Continent" it must “accelerate and intensify” in five key domains, which are discussed in brief below.

1. Computing infrastructure. The EU now has a total of 13 "AI Factories" across 17 EU Member States, and investment in supercomputer infrastructure is expected to reach €10bn by 2027. AI Factories integrate AI-optimized supercomputers, large data resources, programming and training facilities, and human capital to create cutting-edge AI models and applications. With the move towards more complex AI models and even Artificial General Intelligence (AGI), as mentioned at the AI Action Summit in February 2025 (discussed in our Client Alert), the EU plans to also launch various "AI Gigafactories" which will be capable of an “unprecedented level of computing”, to ensure Europe can compete globally. These will require €20bn of investment and the target is to develop five AI Gigafactories across the EU.
2. Data Union Strategy. The Plan discusses the need to enhance interoperability and data availability across sectors for better training of models. While increasing access to data, necessary safeguards for confidentiality, integrity and security of data will need to be implemented. The EC suggests one approach is to streamline existing data legislation to reduce compliance complexity (e.g. the EC intends to soon lay out plans to update the GDPR to make compliance more efficient and predictable for businesses). Additionally, the "Data Labs" shall aggregate data from different AI Factories to ensure that AI developers will have access to large volumes of high-quality data.
3. AI adoption. The EC wishes to increase uptake of AI in strategic sectors such as healthcare, justice, education, manufacturing and public administration to drive growth and enhance competitiveness – an approach labelled the "Apply AI Strategy." This will target key industrial areas of untapped potential where AI can play a role and improve efficiencies. The EC will organise dialogues with industry and public sector representatives to identify sector-specific AI-related deliverables and KPIs to inform its Apply AI Strategy.
4. Skills and talent. The Plan discusses the "AI in Education" initiative which will seek to improve AI literacy in primary and secondary education. The EC also acknowledges the need to develop and enlarge the EU’s talent pool to keep up with the demand for AI-related expertise by re-skilling and upskilling the EU workforce in the use of AI. The EC will also support the roll-out and provision of EU bachelors and masters degrees as well as PhDs focusing on AI, and AI fellowship schemes will enable highly skilled EU and non-EU PhD candidates living outside the EU to work in EU-based entities.
5. Regulatory simplification. The EU AI Act has been developed to ensure a clear set of rules and avoid market fragmentation, which would have negative consequences for businesses and the EU AI ecosystem. However, the EC recognizes the need to also facilitate compliance as businesses not only grapple with a fast-developing technology, but an entirely new set of rules – the EU AI Act is a complex piece of legislation – particularly for small businesses. As such the AI Office will be setting up an "AI Service Desk" where stakeholders can ask for help and receive tailor-made answers. This initiative will provide straightforward and free access to information and guidance on the applicable regulatory framework (noting that stakeholders can already directly engage with the AI Office through the "AI Pact"). Additionally, the AI Office has launched a public consultation to inform its upcoming Apply AI Strategy, which shall remain open for responses until June 4, 2025. The consultation comprises specific questions on the challenges faced by organizations in the EU AI Act implementation process, to identify where regulatory uncertainty is hindering the development and adoption of AI. It is unclear as yet whether the EC does or does not intend to make any modifications to the EU AI Act, particularly against the backdrop of a political and economic landscape that is very different, and continuously shifting, to when the EU AI Act was first drafted and published.

In addition to the above-mentioned consultation, the EC will in Q2 2025 launch a public consultation on the Data Union Strategy in which organizations are encouraged to participate to assist with fine-tuning the proposed actions and crucial next steps.