Written evidence submitted by the British Standards Institution





BSI is responding to this consultation as the UK’s National Standards Body, incorporated by Royal Charter and responsible independently for preparing British Standards and for coordinating the input of UK experts to European and international standards committees. BSI provides the infrastructure for over 13,000 experts, who are the voice of UK economic and social interests, to be influential in the international standards organisations.

BSI operates in accordance with a Memorandum of Understanding with the UK Government and has a public interest responsibility to develop and maintain the standards infrastructure to support UK emerging industries at home and internationally. BSI’s robust standards development process requires open and full consultation with these stakeholders to build consensus-based outcomes. 

As the National Standards Body, BSI represents the UK view on standards in Europe via the European Standards Organizations CEN and CENELEC and internationally via ISO and IEC. BSI is an NSO member of ETSI (The European Telecommunications Standards Institute) and provides support to DCMS as part of the UK membership of ITU (the International Telecommunication Union).

BSI is responding to the consultation questions that are relevant to standards and standardization. We would welcome the opportunity to provide oral evidence to the Science and Technology Select Committee on the role standards can play in future AI governance models.


Inquiry Questions



  1. The government published its National AI strategy in September 2021. The Strategy sets out the government’s plans to strengthen the UK’s position as a global science superpower and seize the potential of AI to improve people’s lives. The strategy also notes the government’s ambition to use digital technical standards to provide an agile and pro-innovation way to regulate AI technologies and build consistency in technical approaches, as part of a wider suite of governance tools complementing ‘traditional’ regulation.
  2. BSI welcomes the government’s ambitions to utilize standards in support of any future regulation. The Strategy recognizes that the integration of standards and assurance in the government’s model for AI governance and regulation is crucial for unlocking the benefits of AI for the economy and society.
  3. Standards and accreditation offer a business and consumer friendly alternative to regulation and enable interoperability in complex supply-chains. Standards that form the basis of industry self-regulation, combined with accredited conformity assessment give the highest degree of confidence in compliance, and demonstrate a clear path to a more effective adoption of best practice.
  4. Within the current governance frameworks of emerging technology, standards help establish governance frameworks that are fit-for-purpose and can incentivize innovation whilst delivering safety, trustworthiness, security, quality, consistency, and efficiency which benefits consumers and businesses. 
  5. The UK, through BSI committee ART/1, is one of the 50 countries working internationally on standards development on critical AI topics of risk management, explainability, bias and functional safety. These standards are global best practice documents that provide businesses with guidance on the implementation and use of AI technology that is built on trust and security.
  6. BSI’s standards development process brings together technical committees of experts who volunteer to help develop standards. These include representatives from industry, professional institutions, trade associations, certification bodies, testing and inspection bodies, research organizations, consumer interest organizations, educational bodies and government departments. Combining these varied interests facilitates ‘market-driven’ innovation and enables user-orientated solutions to be achieved.
  7. One of the new standards currently in development by the committee is the Management Systems standard for AI – known as ISO/IEC 42001. Management System standards provide a framework for organizations on best practice processes and help business incorporate business continuity, cyber security, and quality in implementing AI.
  8. As part of BSI’s role as a convenor of stakeholders, BSI is a strategic partner of the new AI Standards Hub. Led by government and developed alongside ATI and NPL, the AI Standards Hub is being piloted to expand the UK’s thought leadership in the use of AI and AI standards. The Hub will be central to engaging practitioners and building community collaboration to understand the priority areas to focus on in the development, codification, and implementation of standards for AI. The outcomes of the hub will play a key role in clarifying the landscape to identify priorities towards influencing global standards development.



  1. BSI welcomes the government’s approach to develop a pro-innovation, light-touch, and coherent regulatory framework, which can give clarity to businesses and drive new investment, whilst ensuring the development of responsible AI. Standards play a fundamental role in the delivery of this framework by aiding the adoption of responsible technologies.
  2. BSI stands ready to support the UK government in creating a system of AI governance. Standards bodies and regulators need to work closely together to develop an overarching rules-based system of AI governance that can utilize existing standards and identify the gaps and overlaps dependent on application.  This should be an ongoing dialogue which should be maintained and continued after the publication of regulation to ensure that standards can support industry and consumer requirements were needed.
  3. The desire for a proportionate regulatory framework that supports innovation is evident in the Government’s AI policy paper. Going forward there is value in considering how we create incentives for regulators to take risks. This will require those offering new innovative products and services to clearly explain the societal benefit of their offering, assuming it works, and identify the major risks that cause the benefits to be lost/harm created. Regulators can then potentially make broader judgements about acceptability.
  4. Regulatory sandboxes can be used as safe environments for regulators and standards-makers to work together to explore governance solutions that are innovative but at the same time safe and effective. We would recommend government explore more investment opportunity to create platforms for collaboration and testing of AI governance models.


-          Is more legislation or better guidance required?

  1. Drafting legislation for technology that is still evolving is challenging. Capabilities of AI and our understanding of their functionality will change rapidly over the years, and any new regulation will need to be future-proof to allow for these changes.
  2. Regulation should set out the legal requirements of trust, safety, and security. Standards can then help support regulatory guidance by underpinning high-level regulatory objectives with technical or framework specificities that can be adopted by businesses. New legislation will require new standards and guidance documents that help businesses understand how they can implement best practice.
  3. Standards can help guide internal decision making and outline organizational and technical means to meet desired outcomes. This can provide additional certainty for organizations on how they can meet regulatory objectives and utilize best practice across their business.
  4. Whilst legislation can influence behaviors within the UK, international standards are needed to help these behaviors be adopted internationally and help facilitate trust and confidence across global markets. International standards are particularly important to ensure interoperability of markets and reduce regulatory fragmentation that can be caused by national or regional standards.



  1. We would encourage UK policymakers to stay engaged in international discussions on AI regulation, both to learn from the approach of others, ensure alignment where possible, and to influence others in adopting a use-case -specific approach to risk based AI regulation. This includes engagement with the creation and adoption of international AI standards, which will play a major role in regulatory compliance with, for example, the EU AI Act.
  2. The more UK regulators can influence and, where relevant, align with requirements of other jurisdictions, the simpler it will be for any company operating across borders to demonstrate compliance. Clarity of compliance regimes will in turn encourage greater levels of participation in the UK market and leave space for companies to focus on innovation and a thriving start-up ecosystem.





About BSI


BSI is the UK’s National Standards Body, incorporated by Royal Charter and responsible independently for preparing British Standards and related publications and for coordinating the input of UK experts to European and international standards committees.

BSI has over 115 years of experience in serving the interest of a wide range of stakeholders including government, business and society. BSI represents the UK view on standards in Europe (via the European Standards Organizations CEN and CENELEC) and internationally (via ISO and IEC). BSI has a globally recognised reputation for independence, integrity and innovation ensuring standards are useful, relevant, and authoritative.

BSI is appointed by government and responsible independently for maintaining the integrity of the national standards-making system not only for the benefit of UK industry and society but also to ensure that standards developed by UK experts meet international expectations of open consultation, stakeholder involvement and market relevance.

British Standards and UK implementations of CEN/CENELEC or ISO/IEC standards are all documents defining best practice, established by consensus. Each standard is kept current through a process of maintenance and review whereby it is updated, revised, or withdrawn as necessary. Standards are designed to set out clear and unambiguous provisions and objectives. Although standards are voluntary and separate from legal and regulatory systems, they can be used to support or complement legislation.


(November 2022)