Source: EURLEX
Language: en
Format: md

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| OPINION |
| European Economic and Social Committee |
| AI applications/liberal professions |
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| Interdependences between AI applications and liberal professions services: addressing urgent societal needs  (own-initiative opinion) |
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| INT/1083 |
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| Rapporteur: Rudolf KOLBE |
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EN

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| Advisor | Alfred BUTTNER |
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| Plenary Assembly decision | 27/2/2025 |
| Legal basis | Rule 52(2) of the Rules of Procedure |
| Section responsible | Section for Single Market, Production and Consumption |
| Adopted in section | 2/9/2025 |
| Adopted at plenary | 18/9/2025 |
| Plenary session No | 599 |
| Outcome of vote  (for/against/abstentions | 98/0/0 |

1.Conclusions and recommendations

1.1Members of the liberal professions are distinguished by their high levels of professional qualifications, by the personal nature of their service provision and by their particular professional ethics, and they are trusted. These core principles must not be watered down in the era of artificial intelligence (AI). AI must be used in such a way that it complements rather than replaces the work of the liberal professions. The ‘human in command’ principle must always be guaranteed.

1.2AI has the potential to revolutionise many aspects of the liberal professions by improving the efficiency and quality of services while also better meeting society’s needs. However, AI must be used within an ethical and legal framework.

1.3The EU should continue with its approach of promoting and regulating AI, including a legal framework for liability issues, and, specifically, should support AI research and development.

1.4The use of AI requires huge computing power and capabilities. The EU must step up the development of secure European computing and data infrastructure in order to reduce dependencies on non-European providers. This includes developing the digital infrastructure necessary for the use of AI to ensure that modern technologies can be accessed in all regions.

1.5The liberal professions should be involved in AI regulation processes, for example as part of expert forums, standardisation initiatives and ethics committees.

1.6The EU should promote the development and introduction of a European AI ‘quality seal’ for transparent, safe and trustworthy AI applications, which the liberal professions in particular could benefit from.

1.7The EU Member States should expand training course content to include aspects of AI and should enable lifelong learning in this field. Moreover, the EU should promote AI training for the liberal professions through programmes such as Erasmus+, the European Social Fund (ESF) and vocational training.

1.8Furthermore, members of the liberal professions must meet the challenges of using AI by acquiring the qualifications they need to use it responsibly and effectively. Associations and self-governing authorities of the liberal professions should develop AI strategies, adapt their codes of professional conduct and provide their members with AI training.

1.9Social dialogue is important to ensure the use and transparency of AI and explain the objectives behind the introduction of AI tools. The relationship between the tasks to be entrusted to machines and those reserved for people must therefore be the subject of collective bargaining and social dialogue.

2.The importance of the liberal professions in the digital transformation

2.1The liberal professions are of great importance to society. The services provided by doctors, dentists, engineers, architects, lawyers, notaries, tax consultants, accountants, employment counsellors and members of other liberal professions are closely linked to basic needs and fundamental rights such as life, work, health, safety and property, and are a major factor determining people’s quality of life.

2.2Digital applications already constitute an indispensable part of the liberal professions’ services. A particular feature of digitalisation is the fast-growing use of AI, which has the potential to radically alter the activities of the liberal professions. This particularly applies to the core of liberal professions’ services: the special relationship of trust between the members of the liberal professions themselves and their clients, customers and patients.

2.3These professions are facing a variety of challenges as a result of the digital transformation. On the one hand, digital technologies and AI can help improve the efficiency and quality of services. On the other hand, liberal professionals also need to adapt how they work to meet digital requirements, prevent risks and keep pace with advances in automation and the increasing use of AI.

3.Societal needs and AI in the liberal professions: innovation and developments

3.1As in many areas of life, AI applications are spreading in the liberal professions.

3.2In medicine and dentistry, AI is used in a variety of ways in diagnostics and therapy. For example, AI systems are used to analyse imaging techniques, such as X-ray images, in order to detect early signs of disease.

3.3In engineering, AI is mainly used in the automation and optimisation of processes. AI-based systems are employed in the construction of machinery and equipment in order to increase efficiency and precision.

3.4In the legal sphere, AI is employed for researching and analysing legal texts. Another example is the use of AI in drafting contracts and legal documentation. Notaries can use AI-based systems to automate the authentication and management of documents.

3.5In auditing, AI plays a role in analysing financial data and carrying out audits. AI systems can detect anomalies in large amounts of data and thus detect potential fraud and accounting errors at an early stage.

3.6In tax consulting, AI-enabled systems can automate repetitive tasks such as processing supporting documents.

4.Ensuring sustainable quality of life

4.1AI will play an important role in achieving the EU’s sustainability goals under the Green Deal and the New European Bauhaus initiative. This is particularly true in architecture and construction, where it is supporting sustainable construction, efficient use of resources and social participation; it is likewise helping achieve the important objective of affordable housing in the EU.

4.2AI-based planning and construction optimisation systems help to minimise the use of materials and energy consumption during construction and optimise construction processes. AI can support circular economy principles in construction by managing materials more efficiently and optimising the dismantling of buildings for the purpose of recycling and reusing building materials.

4.3It can contribute to the development of smart buildings. Smart building technologies range from controls for heating and air conditioning units to lighting systems that respond to the people’s presence (or absence). This means lower energy consumption and therefore reduced CO2 emissions.

4.4Finally, AI can contribute to the design of sustainable cities by helping to optimise transport flows, select sites for green spaces and integrate sustainable infrastructure projects.

5.Use of AI to improve the quality of liberal professions’ services

5.1It is already clear that AI can make a significant contribution to efficiency gains in the liberal professions. It collects data faster, more accurately and more efficiently.

5.2The integration of AI into professional practice will improve the quality of liberal professions’ services. AI algorithms can analyse large volumes of data and identify patterns that would be difficult for humans to detect. Complex analyses can be carried out in much shorter periods of time.

5.3AI can also help by relieving the burden associated with repetitive, time-consuming tasks. Robotic process automation helps companies with administrative tasks such as invoicing and archiving, which often have to be carried out alongside professional tasks. This leaves more time for more complex, value-adding activities.

5.4AI likewise makes an important contribution when it comes to improving communication, by producing text, image and language, for example through automated translation services.

5.5The impetus for growth arising from AI should not be underestimated. In particular, generative AI – which generates new content on the basis of prompts and existing information – has the potential to yield huge productivity gains.

5.6As a result of demographic change, there is a growing shortage of skilled workers. Human resources are lacking in key service areas such as health and law. AI can play a key role in boosting capacities in these areas. Telemedicine and AI-enabled diagnostic tools, for example, facilitate access to healthcare for patients in remote areas.

5.7As AI can analyse large amounts of data in real time, it can make it possible to gain a broader understanding of customer needs, enabling more targeted communication. It enables continuous, personalised and consistent interaction, thus significantly improving the customer’s perceived experience.

6.A human-centric approach and the necessary qualifications

6.1The growing opportunities offered by AI raise questions relating to the liberal professions and how they view themselves, such as the extent to which the ‘human factor’ can be replaced by smart programmes and machine learning.

6.2In the liberal professions in particular, the use of AI could be perceived as dehumanising. Clients and patients might lose confidence if they felt that their problems were being dealt with by machines rather than qualified professionals. In order to counter uncertainty about AI, forward-looking regulation of the professions is becoming increasingly important as a basis. It must take due account of the specific characteristics of liberal professions’ services in relation to personal responsibility and the public interest in such services, in order to maintain the necessary level of security for consumers, while retaining maximum flexibility.

6.3The use of AI in the liberal professions therefore requires a human-centric approach in which technology serves as a tool to support these professions rather than replace them. This means that the liberal professions must not only have technical knowledge as regards how to deal with AI, but also have the ability to use this technology ethically and responsibly. To enable innovation in the professional regulatory framework, regulatory sandboxes should be set up for the use of AI in the liberal professions. Such controlled test environments could provide valuable insights for regulation and practical implementation.

6.4AI applications must respect the autonomy and freedom of choice of the liberal professions. These systems are only meant to help people make informed decisions, not to bear the ultimate responsibility. The ‘human in command’ principle must always be guaranteed.

6.5AI cannot replace the interpersonal aspects and emotional intelligence that are so crucial to the liberal professions. The ability to solve complex ethical issues, take responsibility and gain client trust remains uniquely human.

6.6It must be possible to understand how and why AI systems produce certain results. The decision-making processes behind AI models should be documented in a transparent, comprehensible manner so as to foster trust and avoid misunderstandings, a concept known as ‘explainable AI’. This is the only way to ensure that personal responsibility for services provided is at the heart of the liberal professions.

6.7A trustworthy framework for the use of AI is essential. Social dialogue and employee participation are important for regulating use, ensuring the transparency of the AI systems used and explaining the biases and objectives behind the introduction of AI tools. The relationship between the tasks to be entrusted to machines and those to be reserved for people must therefore be the subject of collective bargaining and social dialogue.

7.Legal requirements for the liberal professions when dealing with AI – ensuring data protection

7.1The programming and use of AI must respect the fundamental principles of human dignity and equity. There should be no discrimination or inequality of treatment due to incomplete datasets or incorrect algorithms.

7.2Regardless of their competences, national and EU legislators are urged to regulate the use of AI and ensure that AI systems are used not only effectively but also fairly, and that they comply with ethical standards across the EU. An important step could be an ad hoc legal instrument to better address the challenges of AI, in particular transparency, explainability of decisions and accountability.

7.3With Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (‘AI Act’), the European Union launched the world’s first regulation of AI applications and created a European AI Office. The EU’s approach – on the one hand to promote the development of AI and on the other hand to regulate it – should be maintained.

7.4The liberal professions could benefit from the development and introduction of a European AI ‘quality seal’ for transparent, safe and trustworthy AI applications.

7.5The use of AI often requires access to very personal data, such as medical, financial or other highly personal information.

7.6AI must be used in a way that keeps such information safe and confidential. Members of the liberal professions have a key role to play here in guaranteeing their clients and patients AI use that complies with the General Data Protection Regulation (GDPR). In addition, data protection responsibilities in human-AI interaction should be clearly defined. Sector-specific interpretations of the GDPR are needed for the liberal professions with regard to automated advice and decision-making aids. This also goes hand in hand with observing professional confidentiality, which is the cornerstone of almost all liberal professions.

7.7The liberal professions and their associations and other bodies should therefore be involved in AI regulation processes, for example as part of expert forums, standardisation initiatives and ethics committees.

7.8The use of AI requires huge computing power and capabilities. The EU must step up the development of secure European computing and data infrastructure in order to reduce dependencies on non-European providers and ensure European digital sovereignty. Members of the liberal professions must be free to decide whether to use AI tools and, if so, which ones. This requires independent, EU AI solutions with clear licensing and liability rules – a key building block of the liberal professions’ digital sovereignty. The AI Continent Action Plan of April 2025, which aims to make the EU a global leader in artificial intelligence, is vital in this connection. It is important to ensure that the infrastructure necessary for using AI is expanded throughout the EU. There is also a need for economical AI models that consume less energy and require less training data.

7.9At the same time, it is important to ensure that the liberal professions have non-discriminatory access to AI tools. The dominant position of certain technology providers must not restrict innovation, quality or professional independence. Fair and transparent access to digital tools is a prerequisite for equal opportunities and economic resilience.

7.10The spread of AI must not increase the risk of members of the liberal professions becoming dependent on digital platforms that, while providing them with visibility and opportunities, often operate using algorithms that are opaque and not always fair. These mechanisms can introduce elements of arbitrariness and asymmetry that undermine the autonomy and transparency of the relationship between supply and demand. At the same time, AI start-ups are pushing into the liberal professions’ areas of work. This development requires a critical examination of the extent to which such offers should be regulated or given a legal professional classification.

7.11It is essential to determine who owns the rights to works produced using algorithms and how to protect intellectual property from threats and unintentional infringement.

8.Liability in the event of error or damage

8.1From the point of view of the liberal professions, the question of responsibility and liability in the event of damage arising from the use of AI is also of key importance. Clear and proportionate liability rules are needed to maintain users’ trust.

8.2In such cases, the primary responsibility lies with the members of the liberal professions when AI applications are used. They are the ones who bear the ultimate responsibility for decisions. It is on this that the special nature of the relationship of trust is based. AI can serve as a support, but humans remain the ultimate authority when it comes to making decisions and taking responsibility for them.

8.3However, this does not exempt providers and developers of AI systems from their own specific liability. These companies must ensure that their products are safe, reliable and ethically sound. If an error occurs in an AI system, it must be clear in which circumstances the developer is liable for any damage caused and in which circumstances the provider or the user of the system is liable.

8.4It should be highlighted that, regrettably, the European Commission withdrew its 2022 proposal for the creation of an AI Liability Directive in April 2025, as discussions on the matter stalled. Given the importance of the issue, a new attempt should be made to regulate this critical area.

9.AI-related qualifications and training

9.1The use of AI requires the liberal professions to develop new skills and competences. Qualifications for operating in the liberal professions need to be broadened so that professionals both master the technical aspects of AI and are able to deal responsibly with the ethical implications of using it.

9.2To this end, members of the liberal professionals need to be equipped with the relevant digital skills from their initial training onwards. This includes employees working in the liberal professions whose training comes under the responsibility of the professionals concerned.

9.3The same applies to further and ongoing training relating to the liberal professions. A commitment to lifelong learning is needed to ensure the acquisition of rapidly changing digital skills. This includes training on explainability, data governance and the risks of biased results in automated decision-making aids. Training on AI should be tailored to the needs of the relevant profession.

10.AI and self-regulation in the liberal professions

10.1One key feature of the liberal professions is one form or other of professional organisation; these bodies vary from one Member State to another.

10.2The increasing use of AI therefore creates new tasks for professional chambers and associations of liberal professions. They can help their members develop new digital business areas and work with new media and they can set up specialised training courses.

10.3Professional chambers and associations should take the lead in AI governance, proactively update their codes of ethics and codes of professional conduct and adapt their practical guidelines for the responsible use of AI to ensure that those working in the liberal professions always use their professional judgement and do not blindly rely on AI. The liberal professions should develop AI strategies for their respective professions.

Brussels, 18 September 2025

The President of the European Economic and Social Committee

Oliver RÖPKE

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