C Explanatory memorandum by Ms Larysa
Bilozir, rapporteur for opinionNote
1. I welcome the report prepared
by Ms Marietta Karamanli (France, SOC) for the Committee on Political Affairs
and Democracy on “The role of the OECD in evaluating the impact
of artificial intelligence on the future of work” (
Doc. 16472). The report offers a comprehensive and timely overview
of how AI is reshaping labour markets, education and training, the
creative industries and media, and the public sector across Council
of Europe and OECD member States, and rightly calls for a human-centred,
rights-based approach to the AI and digital transition.
2. As rapporteur for opinion on behalf of the Committee on Migration,
International Protection and Economic Co-operation, I would like
to draw the Political Affairs Committee’s attention to a substantial
body of work that our committee has itself carried out on the specific
intersection of AI and migration – work that predates and directly
informs several of the questions raised in the draft resolution.
3. On 3 October 2025, the Assembly adopted
Resolution 2628 (2025) and
Recommendation
2300 (2025) “Artificial intelligence and migration”, on the basis
of the report prepared by Mr Petri Honkonen (Finland, ALDE) for
the committee.
Note The resolution addresses the
use of AI across the entire migration journey – from border management
and visa processing to biometric identification, integration support
and, importantly, labour-market access – and calls for AI systems
in this field to be lawful, safe, non-discriminatory, transparent
and subject to meaningful human oversight.
4. In
Recommendation
2300 (2025), the Assembly urged the Committee of Ministers to prepare
a dedicated recommendation guiding member States on the use of AI
in migration management, including a code of good practice. In its
reply of 29 April 2026,
Note the Committee of Ministers welcomed
the Assembly’s work and confirmed the centrality of the Council
of Europe Framework Convention on Artificial Intelligence and Human Rights,
Democracy and the Rule of Law (CETS No. 225), but did not commit
to elaborating such a dedicated instrument; instead, it pointed
to the Handbook on Human Rights and Artificial Intelligence adopted
by the Steering Committee for Human Rights (CDDH) in November 2025,
Note which
addresses immigration and border control as one of several sectors
of public governance. In his analysis,
Note the committee’s rapporteur noted that the
Committee of Ministers’ reply understands “migration management”
mainly as immigration and border control, whereas the Assembly’s
own resolution conceives of migration management as covering the
whole migration journey, including labour migration and integration.
The committee will continue working on this issue, towards a comprehensive,
migration-specific recommendation.
5. This body of work is directly relevant to the draft resolution
under consideration, which examines the impact of AI on the future
of work in general terms but does not currently address the specific
situation of migrant, refugee and other foreign workers, even though
these groups are among those most exposed to the risks that AI presents
in the labour market.
6. The draft resolution rightly notes, in paragraph 12, that
the adoption of AI tools in the workforce may exacerbate existing
inequalities among workers, citing the particular exposure of women,
young people and older workers. I consider that this analysis could
be usefully extended to explicitly cover migrants, refugees and asylum
seekers, who face comparable – and in some respects compounded –
risks of exclusion and discrimination where AI-based tools are used
without adequate safeguards for recruitment, identity verification, skills-matching,
or decisions on residence and work permits that directly affect
their livelihoods and legal status (Amendment A).
7. Secondly, paragraph 20 of the draft resolution sets out a
substantial list of measures that member States of the Council of
Europe and the OECD are invited to take regarding the impact of
AI on labour markets. This list, however, does not address the distinct
risks that AI-based tools pose when used in recruitment, employment
and residence or work-permit procedures affecting migrant workers
specifically – contexts in which the consequences of biased or unaccountable
automated decision making can be particularly severe, given the
direct link between such decisions and a person’s right to remain
and work in a country. I therefore propose a new paragraph requiring
that such tools be subject to meaningful human oversight, be regularly audited
for discriminatory bias, and comply with applicable international
human rights and data protection standards, in line with Resolution
2628 (2025) (Amendment B).
8. Thirdly, and closely related, I propose a further new paragraph
addressing the risk that AI-driven labour-matching and job-allocation
tools could reinforce, rather than reduce, the occupational segregation
of migrant, refugee and other foreign workers into low-quality or
precarious jobs – a well-documented labour-market phenomenon that
predates AI, but that automated matching systems risk entrenching
if they are trained on historical placement data. The amendment
instead calls for such tools to be designed and monitored so that they
actively support fair access to employment matching migrant workers’
actual qualifications (Amendment C).
9. Finally, paragraph 24 of the draft resolution invites the
OECD to continue and deepen its work on measuring and evaluating
the impacts of AI, and to strengthen its co-operation with the Council
of Europe. Paragraph 25 goes into the specifics. I propose adding
a sentence to that paragraph inviting the OECD’s future work to
give due consideration to the specific situation of migrant, refugee
and cross-border workers (Amendment D).
10. I sincerely hope that the Political Affairs Committee will
accept these amendments, which are intended not to alter the balance
or ambition of an otherwise exceptionally comprehensive report,
but to ensure that the Enlarged Assembly’s position on AI and the
future of work fully reflects the recommendations the Assembly has
itself already adopted in the field of AI and migration, and that
the specific situation of migrant, refugee and other foreign workers
– who number in the tens of millions across Council of Europe and
OECD member States – is not overlooked in the broader response to
AI and the digital transition.
