NFU Position Paper on AI regulation

Executive summary

This paper presents the Nordic Financial Unions’ (NFU) position and recommendations regarding artificial intelligence (AI) regulation, particularly in relation to employment and workplace rights. While the EU Artificial Intelligence Act (AI Act) sets out requirements for AI systems in high-risk employment contexts, there remains uncertainty regarding its implementation in employer-employee relationships.

During autumn 2024, the European Commission conducted a targeted consultation on the use of AI in financial services. NFU emphasized that the success and acceptance of AI systems in the financial sector depend on employee involvement and co-determination, in line with existing company-level agreements on performance management, metrics, and data usage.

Employees in the finance industry work in highly digitized environments, where datadriven performance tools and analytics are commonplace. However, the introduction of AI based management tools must not result in work intensification, increased competition, or reduced professional autonomy. AI tools in the workplace should be used to free their potential to increase benefit and well-being of employees.

One critical gap in the AI Act is that it does not guarantee worker rights, nor does it provide specific transparency, involvement, or influence mechanisms for employees.