What seems like technical paperwork actually shapes where Europe’s AI rules are written. ARTICLE 19’s latest guide lifts the lid on the functioning of the EU’s official standardisation bodies – CEN and CENELEC – and outlines ways in which civil society can engage with them to mitigate industry capture and advocate for technical standards that protect human rights.
The standards developed by CEN (Comité Européen de Normalisation) and CENELEC (Comité Européen de Normalisation Électrotechnique) translate high-level EU legislation into the concrete technical requirements companies must meet. These standards determine how organisations demonstrate compliance with regulation.
This makes technical standardisation not just a commercial activity – it’s also a form of shadow legislation. Right now, the experts developing standards are determining how fundamental rights protections will operate across AI systems in the EU, with implications that could potentially extend worldwide.
The power imbalance – why civil society engagement matters
CEN/CENELEC standards are drafted in working groups composed of technical experts. These experts’ participation is typically supported by their employers, most often companies.
Many stakeholders outside the private sector struggle to participate in CEN/CENELEC. Limited transparency, non-transparent frameworks, and resource-intensive processes make it challenging for civil society organisations to engage, giving industry a structural advantage. Large tech companies can send multiple experts to working groups, attend meetings consistently, and coordinate across drafts and votes, shaping discussions from the start.
Despite this, civil society can still engage. Our guide presents 4 pathways, highlighting the pros and cons of each approach:
- Participate through CEN/CENELEC public interest networks. These official liaison bodies can join any CEN/CENELEC Technical Body or Working Group.
- Join one of the National Standards Bodies (NSB). NSBs are the most powerful and influential stakeholders in CEN/CENELEC processes.
- Become a Working Group expert. Nomination by an NSB allows direct participation in CEN/CENELEC’s standards development process.
- Obtain liaison status. Liaison organisations can join a specific Technical Committee and gain access to working documents and technical meetings.
Technical decisions are never just technical. They embed assumptions about risks, priorities, and acceptable harms directly into the systems that increasingly shape social and economic life. Every algorithm, data standard, or risk metric reflects choices about what – and who – matters. These decisions influence whose opportunities expand, whose freedoms shrink, and whose harms become acceptable.
Standardisation may seem technical, but it is a critical site of governance. Civil society must engage to ensure human rights and the public interest are not sidelined, and that digital technologies – and their standards – benefit society as a whole.