BSA submission on the European Commission’s draft Implementing Regulation under the AI Act outlines the proposed procedural framework for enforcing the regulation, including the evaluation of general-purpose AI models and the conduct of Commission investigations. It highlights key elements, including the Commission’s powers to access models, the role of independent experts, and the rules governing proceedings, fines, and rights of defense. The submission emphasizes the importance of ensuring legal certainty, proportionality, and strong safeguards for confidentiality and due process in the implementation of the AI Act.