AI strategy for cultural and creative sectors

AI systems enable new opportunities in the cultural and creative sectors (CCS), but they also represent unprecedented threats to human creativity, cultural and creative rights, and working conditions. Within this context, Culture Action Europe (CAE) welcomes the European Commission's proposal for an AI Strategy for the CCS.

AI only does it badly, destroys the minds of the youngest, steals art and creates horrible imagines. To initiate, you do not have any system that refuses photos of minors, children or babies, you do not restrict the creation of pornography of all kinds, you violate privacy, and you can create compromising images of minors or anyone to diffuse it.

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The Centre for European Policy Studies (CEPS) welcomes the opportunity to contribute to the consultation. Our feedback is attached and draws on CEPS broader work on the Apply AI Strategy and AI governance, with a specific focus on the cultural and creative sectors and their role in shaping human-centred AI adoption.

European Commission publishes call for evidence on AI strategy for the Cultural and Creative Sectors 1. Contribution from the Chair of Digital Humanities (Image/Object), Friedrich Schiller University Jena The Chair of Digital Humanities (Image/Object) at Friedrich Schiller University Jena welcomes the Commission’s objective to develop a holistic AI strategy that strengthens human agency, cultural and linguistic…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Svenska Fotografers Förbund (SFF) is the national professional association for photographers in Sweden. SFF welcomes a dedicated AI strategy for the cultural and creative sectors. Photography has always developed through technology, and many photographers already use AI-assisted tools. The issue is under what conditions AI is developed and used.

As a graphic designer and illustrator I find it difficult to believe that this initiative will not infringe copyright from artists and designers since the AI models need to be train somehow. You mentioned that one of the ways to train the model is through common European data space for cultural heritage, but through what kind of model provided by what company, and what are the profits/consequences behind that?

I welcome the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors and strongly support an approach in which AI complements human creativity, protects cultural diversity and rights, and strengthens Europes cultural sovereignty.

Regional Initiative for Culture and Creativity (RICC) is an EU platform driven by European Regional offices working in close cooperation with decision makers and experts from their Regions to advocate on cultural creative policies with a territorial dimension, to participate in relevant EU funding programmes, to work under Smart Specialisation Ris3 guidance.Gathers over 30 EU Regions and local authorities since…

Cloudflare welcomes the opportunity to provide evidence to the European Commission on its planned AI Strategy for the Cultural and Creative Sectors. Cloudflare is a leading connectivity cloud company providing security, performance, and reliability services to millions of websites and applications globally.

As a worker in the European cultural sector and a member of several professional associations of translators, I oppose this initiative for the following reasons: 1. Generative AI, in its current form, requires the mass looting of cultural material without permission or remuneration for the training of its models.

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As the largest network of publicly funded theatres in Europe, the European Theatre Convention (ETC) supports the initiative of the European Commission to develop a dedicated AI strategy for the cultural and creative sectors.

Ishiki Studios is an independent, impact-driven creative studio working across film, emerging technology, ecology, well-being, collective action, and ancestral knowledge. Across our five lenses; Prana, Biosphere, Synapse, Rise, and Ancestor, we explore the way to remain deeply human while creating the future.

AI Chamber’s Position on the AI Strategy for the Cultural and Creative Sectors AI Chamber supports the development of a European strategy that combines the advancement of artificial intelligence with the protection of creators and the strengthening of cultural diversity. AI can support content creation, translation and dissemination, heritage preservation, and the development of new services.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Music Tech Netherlands (MTNL) welcomes the European Commission's call for evidence on an AI strategy for the cultural and creative sectors. MTNL brings together actors at the intersection of music and technology (from artists, venues and other music professionals, to technology developers, knowledgeinstutes and governmental bodies to drive innovation rooted in the needs and ambitions of the music sector.

IFPI is the voice of the recording industry worldwide, representing over 8,000 record company members across the globe. We work to promote the value of recorded music, campaign for the rights of record producers and expand the commercial uses of recorded music around the world. Attached please find IFPI's input for this call for evidence.

The European creative fashion sector welcomes the opportunity to contribute to the EU reflection on AI and copyright and calls for a framework that supports innovation while preserving the fundamental rights of creators and rights holders. 1. Adapting copyright to Artificial Intelligence The sector calls for clear statutory rules governing AI model training and meaningful, verifiable transparency.

AI Strategy for CCS should take into account the needs and opportunities for cultural, heritage and creative tourism. In particular, the EU Smart Tourism and UN Tourism Smart Destinations initiatives recognise that cultural heritage and creativity are important components.

Open Nederland and Open State Foundation believe that knowledge, culture, and technology should be freely available to share, study, modify, and build upon. We advocate for open data, open source software, digital sovereignty, and a robust public domain. 1. Public Money, Public Ownership EU public funding must require that the development or implementation of AI systems are fully available to the public.

AI Strategy for the Cultural and Creative Sectors: Call for Evidence. Submission of evidence from: Dr. Jenny Kidd, School of Journalism, Media and Culture, Cardi: University. Kiddjc2@cardi:.ac.uk Dr. [name removed], Department of Digital Humanities, King’s College London. [email removed] Introduction [1] We welcome the European Commission’s development of an AI Strategy for the Cultural and Creative Sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Insufficient AI regulation puts the creative sector at risk. The high social, environmental and, above all, democratic costs of an insufficiently regulated AI boom are a recurring topic of public debate. Cultural costs, on the other hand, have so far hardly been reflected in this context. This concerns in particular the use of Large Language Models (LLMs) in the text-centric creative and media industries.

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EIT Culture & Creativity is the Knowledge and Innovation Community of the European Institute of Innovation and Technology (EIT) dedicated to Europe's cultural and creative sectors and industries (CCSI). It connects research, education, business, investors, cultural institutions and public authorities across Europe to turn creativity, knowledge and intellectual property into innovation, companies, skills and societal…

Please open our attached file for the full feedback of our submission. In our submission, we start by stressing the importance of respecting and enforcing intellectual property rights. In this context, we will focus in particular on the text and data mining exceptions from the CDSM Directive.

We are writing as a collective of practitioners, technologist, and policy advisors who's mission is to design futures where digital ecosystems coexist with nature and humans. Our contribution to this Call for Evidence comes out of 2 years of research dedicated to where responsible AI fits in the lives of arts practitioners.

La IA generativa no debería abordarse únicamente como una amenaza para los sectores culturales y creativos, sino como una herramienta más dentro de una larga historia de tecnologías que han ampliado las posibilidades del arte. Proteger a los creadores no puede significar restringir a aquellos creadores que libremente deciden utilizar nuevas herramientas.

I submit this contribution as director of Cultural Sector of the city hall of Barcelona and a PhD in Law specialising in intellectual property and cultural policy. The proposed Strategy is an important opportunity for the European Union to address AI in the cultural and creative sectors not only as a question of technological adoption or copyright compliance, but as a matter of cultural policy.

IA probably works in some things, other things, but art? Really? Creative and intelectual elements of artists literally are stole for this. Doesn't work to create art, to create handmade, handworking, is that, for hand, for people, for human, not a robot.

The German Association of Journalists (DJV) represents around 25.000 members, making it the largest advocacy body for full-time journalists in Germany and Europe. The DJV welcomes the initiative of an AI strategy for the cultural and creative sectors. Journalism makes an indispensable contribution to democratic opinion-forming and cultural and linguistic diversity in Europe.

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PRS for Music welcomes the opportunity to respond to the European Commissions call for evidence to shape the forthcoming AI strategy for the cultural and creative sectors (CCS). We refer the EC to our attached file for the full submission. Summary: AI has already had a profound impact on the way music is created, distributed and consumed.

The Argentinian Association of Doctors points to the following negative effects and their impacts on the profession due to the use of Generative Artificial Intelligence. The ability of these IAs to reproduce the particular styles of living artists, using their own names and works within the prompts to imitate them without their consent or remuneration.

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AI is trained with the work of millions of professionals, without rewarding them financially or mentioning them. And now, it is destroying millions of jobs for the benefit of a few companies. We need responsible regulation, limiting the use of AI to being an assistant and never being able to replace a professional.

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Mistral welcomes the Call for Evidence for an AI Strategy in the Cultural and Creative Sectors and the Commission's ambition to place culture at the heart of Europe's digital transition. We share the Commission's ambition to make innovation and competitiveness central to this transition, and welcome its recognition that closer collaboration between Europe's cultural and creative sectors and European AI developers…

Creativity is not a free raw material for AI. As a marketing advisor, writer, designer and creative head, I welcome innovation. AI can support my work, accelerate processes and open up new creative opportunities. But one thing must not be lost: Creativity has an creator. And creative work has value. AI systems learn from text, images, concepts, campaigns, designs and other works that humans have created.

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I rrally think AI is good tool for different types of work. It is really good for organizing information and for assiting on every type of work you are doing. Things said, we are talking about a tool that is somehow recent and it is not so well regulated. Right now almost everything can be done with IA and when we look at Generative AI, it may be driven toward creating deepfakes and fake news.

Amazon welcomes the opportunity to contribute to the European Commissions Call for Evidence on an AI Strategy for the Cultural and Creative Sectors. We are strongly aligned with the high-level objectives and main orientations confirming that AI should complement and not replace human creativity and agency, and AI should be used to support progress and facilitate broader access to culture and knowledge.

"FUIS (Federazione Unitaria Italiana Scrittori) fully endorses the position taken by EWC regarding the use of protected works with the aid of the AI. We are living through a period of epochal change that we cannot obstacle but that we must manage. The AI must be utilised in the right way, yet without trampling on the rights that authors have secured over the years through great effort.

Hey. I am convinced that AI is a technological advance that helps us complete tasks faster and helps us speed up processes. However, there is no regulation that puts a brake on the acceleration it causes; there is no practical regulation to help us discern which processes should be automated and which should not.

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AI should be understood not only as a tool for increasing productivity, but as a component of hybrid cognitive ecosystems in which human creativity, collective intelligence and artificial intelligence interact. In the Cultural and Creative Sectors, its value lies especially in supporting co-design, access to knowledge, participation and more informed decision-making, while preserving human agency and responsibility.

Please find enclosed the contribution of the General Delegation of Quebec in Brussels and for the European institutions, on behalf of the Government of Quebec (Canada), to this consultation carried out by the Commission on a future European AI Strategy for Culture and Creation.

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It is good that these issues are considered and taken forward at EU level. AI is a new technology that poses a serious threat to human meaning and relevance and can no longer be reversed. It would be important to have AI-generated and AI-edited content identified so that e.g. streaming services can search for identification and, where appropriate, place AI Generated/AI Enhanced, etc.

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With more than 800 members, the German DVV is one of the largest active and solidarity-based professional networks in the German film industry and, as an association, represents the interests of scriptwriters in all matters of film and media policy, promotion, copyright and the negotiation of common remuneration rules with broadcasters, streaming services and production companies.

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RESPONSE TO CALL FOR EVIDENCE AI Strategy for the Cultural and Creative Sectors Ref. Ares(2026)7389748 — European Commission, Directorate-General for Education, Youth, Sport and Culture Submitted by Nathalie Lethbridge, Founder, Atonik Digital · September 2026 I welcome the opportunity to respond to this Call for Evidence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Microsoft's Response to the European Commission's Call for Evidence AI Strategy for the Cultural and Creative Sectors Microsoft welcomes the Commission's initiative to develop an artificial intelligence strategy for the cultural and creative sectors (CCS) as a flagship deliverable of the Culture Compass for Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I think AI should not be used in art under any circumstances. It shouldn't be used at all, given the terrible consequences it's having for the planet of which we only have one. But, specifically in art, AI has no use and should never be used. People spend their lives perfecting their craft, and AI in art is disrespectful to them and to the human race as a whole.

The Federal Association of Interpreters and Transformers (Bundesverband der Dolmetscher und Übesetzer e.V. – BDÜ) takes advantage of the opportunities of so-called artificial intelligence for the cultural and creative sectors.

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11 September 2026 EPC Contribution on the call for evidence on AI strategy for the Cultural and Creative Sectors 1. The European Producers’ Club and Independent producers: • • • The European Producers’ Club (“The EPC”) has, as members, around 200 independent film and television production companies across the Member States of the European Union and the Council of Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a Belgian expert in cultural policy and copyright, teaching and publishing, I confirm that a new strategy for the cultural and creative sector is absolutely urgent and necessary in the face of the emergence of commercial generative AI. The negative impact on occupations, income and the exercise of recognised rights is already significant and increasing.

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The impacts of believing the so-called inevitable and thus necessary growth of generative AI is irresponsible and contradictory to all worthwhile European values, it goes against freedom, justice, equality, future generations, healthy environment, healthy relationships, media literacy and sustainable and solitary economies.

This response from the Centre for Future Generations (CFG) contributes to the European Commission's call for evidence for an AI Strategy for the Cultural and Creative Sectors (CCS), launched on 27 July 2026. CFG is a Brussels-based independent think-and-do tank supporting decision makers in responsibly governing rapid technological change in the interests of current and future generations.

Michael Culture Association welcomes this timely initiative by the European Commission. Together with Culture Action Europe, we coordinate the Digital & AI Action Group, composed of over 140 members of both organisations, aiming at understanding and shaping the impact of AI and the digital transformation on Europe's cultural and creative sectors (CCS).

CW! Submission to the European Commission’s Call for Evidence on the AI Strategy for the Cultural and Creative Sectors We, as Creativity Works!, the leading coalition representing Europe’s cultural and creative sectors, welcome the European Commission’s call for evidence on an AI Strategy for the Cultural and Creative Sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ubmission from DeepL SE for the AI Strategy for the Cultural and S Creative Sectors Initiative eepL is a European AI company specialising in developing high-precision neural machine D translation and real-time voice-to-voice translation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NVPI (the trade association of record companies in the Netherlands) welcomes the Commissions aims to enhance the resilience, competitiveness, and sustainability of Europes creative economy. Europe's music industry is supported by a clear legislative framework, which is vital to business certainty and local investment.

September 2026 Video Games Europe response to the European Commission’s Call for Evidence on an AI Strategy for the Cultural and Creative Sectors Transparency Register Identification Number: 20586492362-11 Introduction Video Games Europe welcomes the European Commission’s Call for Evidence and the preparation of an EU strategy on artificial intelligence in the cultural and creative sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pearle*-Live Performance Europe welcomes the European Commission's initiative to develop a dedicated Strategy on Artificial Intelligence for the Cultural and Creative Sectors. Pearle* is the European federation representing over 13,000 organisations and companies in the music, performing arts and live performance sectors.

Eurocities welcomes the development of a European AI strategy for the cultural and creative sectors. Cities and municipalities have a particular role to play: they operate and fund local cultural and heritage infrastructures, they run public venues (from public venues and local artistic ecosystems to museums, archives and historic sites), they fund local artistic ecosystems, and they directly navigate the economic…

As a member of the Federation of Associations of Professional Enlighteners (FADIP), and a worker in the European cultural sector, I oppose this initiative for the following reasons: 1. Generative AI, in its current form, requires the mass looting of cultural material without permission or remuneration for the training of its models.

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We are filing these comments on behalf of the Alliance for Responsible Innovation in the Arts & Media (ARIAM), a global coalition of content creators and technology providers dedicated to ensuring that artificial intelligence is developed, deployed, and used for the betterment of all society.

Commission document 090166e531adb21b.pdf sets out a long overdue vision for the use of AI. However, as a freelance architect and urban planner, I see a blind spot in the strategy: physical space and our analogue resilience. The current AI revolution raises questions that go far beyond the potential for efficiency gains highlighted in the EU paper.

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BEUC considers that consumer protection should be a central pillar of this strategy. The debate has so far focused on creators, rightsholders and AI providers, while consumers, as the audiences and purchasers of cultural content, have received far less attention.

Open Future welcomes this initiative and the Commission's recognition that AI is reshaping how Europeans reach culture and knowledge. Open Future is a think tank working on public-interest AI and the digital commons. We contributed to the Europeana Initiative's Public AI white paper and support both it and Europeana's response to this Call for Evidence.

1 (2) 2026-09-11 Music performers in Sweden: Joint Response by SAMI, Symf and SMF to the Call for Evidence for an AI strategy for the Cultural and Creative sectors The Swedish Artists’ and Musicians’ Interest Organisation (SAMI)1, the Swedish Musicians’ Union (SMF)2 and the Swedish Union of Professional Musicians (Symf)3 together represent over 65,000 music performers in Sweden.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ladies and gentlemen, please find attached our opinion on an AI strategy for the cultural and creative sectors. FREELENS is the professional association of self-employed photojournalists and photographers in Germany with over 2100 members. Executive summary – The EU should enshrine the preservation of human creativity as an objective of its AI and cultural policies.

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The European Music Managers Alliance (EMMA) represents music managers and the artists they work with across Europe. We submit our attached joint letter, Artists and Songwriters Must Not Be Pressured into AI Deals Without Meaningful Consent, to highlight dangerous practices developing in the music sector and the urgent need for Commission action.

Contribution à la consultation publique « AI Strategy for the Cultural and Creative Sectors (CCS) » L’Alliance de la Presse d’Information Générale regroupe plus de 300 titres de presse quotidienne nationale, quotidienne régionale et départementale, ainsi que de presse hebdomadaire régionale.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Good afternoon. I am pleased that this option is possible, to be able to give feedback about the current matter, AI. I understand that it is being a very big help in science and medicine and also with investigations, I get it has its good side. But when in the wrong hands (wich is so terribly easy) or over used, it becomes bad. Not to mention the catastrophic consequences it is having on our planet.

ADOBE | Response to European Commission Call for Evidence: AI Strategy for the Cultural and Creative Sectors Ref. Ares(2026)8662355 - 11/09/2026 Page 1 ADOBE INC. 11 September 2026 Response to the European Commission Call for Evidence AI Strategy for the Cultural and Creative Sectors 1. Introduction At Adobe, our mission is to empower everyone to create.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As AI transforms the audiovisual sector, the challenge for policymakers is to ensure that its adoption remains economically sustainable. This transformation will have implications for the entire cultural and creative value-chains, including audiovisual creators. In the life cycle of an audiovisual work, producers develop the original idea, secure the financing, and carry the risk.

Submission to the EC call for evidence on its AI Strategy for the Cultural and Creative Sectors I. Empowering creatives through collaborative Innovation II. Unlocking Economic Value, Cross-Border Reach, and Cultural Heritage III.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CFC welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors. CFC is the collective management organisation representing authors and publishers in the book and press sectors. 1.

I have worked in the creative sector for over 20 years, specifically in the arts and in film. In both sectors, in the last few years, I have seen how AI has been used by creative professionals both as a tool for work (in the sense that the product of AI is not the end product); and also as a product in itself. The use of AI raises many concerns. For one, authorship is a big concern.

The CoSTAR Network welcomes the European Commission's initiative to develop a strategy for the use of Artificial Intelligence (AI) in the cultural and creative sectors and industries. Building on initiatives including the AI Act, Europe has an opportunity to champion a vision for creative-led AI and AI for creativity.

Vienna’s demands for professional photography to represent the interests of 3000 professional photographers in Vienna The EU should enshrine the preservation of human creativity as an objective of its AI and cultural policy. Generative AI must not permanently destroy the economic and social foundations of human creative work.

Filed in German · English published by the European Commission

Introduction As a Hungarian citizen, I welcome the European Commissions ambition to treat culture not merely as a sector requiring support, but as a strategic resource for European unity, democracy, social cohesion, innovation and competitiveness.

Filed in Hungarian · English published by the European Commission

EBU position – European Commission’s AI Strategy for the Cultural and Creative Sectors – Call for evidence Public Service Media play a central role in safeguarding democracy, culture and social cohesion in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Svenska Tecknare Association of Swedish Illustrators and Graphic Designers Hantverkargatan 45,K Ares(2026)8661336 - 11/09/2026 SE-112 21Ref. Stockholm, Sweden T: [phone removed] www.svenskatecknare.se Svenska Tecknare svar på Call for evidence Presentation av Svenska Tecknare Svenska Tecknare är en intresseorganisation för professionella illustratörer, grafiska formgivare, animatörer, serietecknare och…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of the Architects Council of Europe - the representative organisation of the architectural profession at European level we would like to share the following feedback. Architecture occupies a distinct position within the CCS.

Europes cultural and creative economy, dominated by micro-enterprises, independent practitioners, and public-interest institutions, stands at a critical juncture where general-purpose artificial intelligence is fundamentally reorganizing how cultural knowledge is generated, monetized, and preserved.

ALMA is the trade union of scriptwriters in Spain, a professional organisation of the majority and most representative scriptwriter in Spain and one of the most numerous in the country and also internationally, with more than a thousand members. On the one hand, we question the assumption raised in this consultation that AI can enrich the cultural artistic and creative process.

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As a member of the Federation of Associations of Professional Enlighteners (FADIP), Vice-President of the Association of Professionals in the Enlightenment of Asturias (APIAST), a worker in the European cultural sector (my presentation agency is based in the UK and USA), and mother I oppose this initiative for the following reasons: 1.

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IMPALA is the European association of independent music companies, representing over 6000 music SMEs across 33 European markets. We welcome the EUs plan to develop an AI strategy for the cultural and creative sectors, based around the guiding principles listed in the call for evidence : technology at the service of culture, support to human creation, creators rights and cultural diversity, sustainability of the…

AI Strategy for the Cultural and Creative Sectors Contribution to the European Commission’s Call for Evidence Submitted by GEMA Ref. Ares(2026)8660720 - 11/09/2026 11 September 2026 GEMA welcomes the opportunity to contribute to the European Commission’s Call for Evidence on the AI Strategy for the Cultural and Creative Sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Well-used and regulated AI can be beneficial. The problem is that it is not circumscribed, regulated or controlled. In addition, data centres contribute to destroying ecosystems, filling up all energy macro-industries to provide the fuel needed for them to function and contribute to desertification at a key moment for climate change. Which we prefer?

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ACT, the Association of Commercial Television and Video on Demand Services in Europe, represents Europes leading commercial broadcasters and on-demand services. Our members finance, produce, promote, and distribute content and services that reach millions of Europeans across all platforms.

ENCATC welcomes the European Commissions preparation of an Artificial Intelligence Strategy for the Cultural and Creative Sectors. The strategy is being developed at an important point in the implementation of European AI policy. The EU AI Act provides a horizontal regulatory framework applying across sectors.

EFAD Response to the Call for Contributions on the EU AI Strategy for the Cultural and Creative Sectors The European Film Agency Directors (EFAD) represents 38 European film agencies, public bodies responsible for national public funding for the film and audiovisual sectors across Europe. EFAD welcomes the European Commission’s initiative for an AI Strategy aimed at the cultural and creative sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Society of Audiovisual Authors (SAA) supports an EU AI Strategy for the Cultural and Creative Sectors in which AI complements, not replaces, authors creativity, strengthens access to culture and knowledge, and supports original European works.

Ladies and gentlemen, we would like to thank you for the opportunity to respond to the Call for Evidence on an AI strategy for the cultural and creative sectors. Please find enclosed the opinion of the VG Bild-Kunst. We represent over 70.000 creators from the visual work areas. Please do not hesitate to contact us if you have any questions and we look forward to a fruitful exchange. Best regards, [name removed] (CEO)

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EARE welcomes the opportunity to contribute to the EUs AI Strategy for the Cultural and Creative Sectors (CCS). Our nine members include university libraries, library associations, archives, technology companies and start-up representatives. They are both custodians of Europes cultural heritage and active users and developers of AI. Libraries, archives and research organisations are important AI innovation partners.

Stockholm, 11 september 2026 Introduction The Swedish Union for Performing Arts and Film (“Scen & Film) represents performing artists, professional authors as well as technical and administrative staff working in the Swedish performing arts, film, radio, television and cinema sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The International Music Council (IMC) is submitting its contribution (attached) in its capacity as lead partner of the Fair Music Project, an EU co-funded initiative. Our submission draws on the Fair Music consortium's experience in developing and testing the Fair Music Beta, and sets out recommendations organised around three connected principles: authorisation, remuneration and transparency.

Artificial intelligence strategy for the cultural and creative sectors Call for evidence1 - Feedback period 27 July 2026 - 11 September 2026 (non-legislative initiative) EUROCOPYA’s contribution EUROCOPYA is the European Association of Audiovisual & Film Producers' private copy collective management societies. EUROCOPYA notably represents the interests of audiovisual producers in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Maison Européenne des Auteurs et des Autrices European Authors House Rue du Prince Royal, 85 1050 Brussels Belgium Dialogue partner of the European Parliament and the European Commission Nr. 5172846104583-18 European Commission Directorate-General for Education, Youth, Sport and Culture Directorate-General for Communications Networks, Content and Technology Brussels, Belgium Vienna, 11th of September Re: Public…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Artificial intelligence can be a very useful tool as long as it is complementary and does not replace human projects and work, as is the case with art; generative AI should be banned; since it is often misused and can be dangerous, such as when used to create nudes of real people.

BZDV - Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP - Medienverband der freien Presse e. V. Comments on the Call for Evidence – Artificial intelligence strategy for the cultural and creative sectors 8 September 2026 Our feedback will address four dimensions of key relevance for press publishers, which should be fully reflected in the Strategy, namely (i) safeguarding the role of the free press in…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

eco welcomes the European Commission's initiative to develop a dedicated AI strategy for the cultural and creative sectors (CCS). We share the Commission's ambition, as set out in the Culture Compass for Europe, to harness digital transformation for the benefit of European culture and creativity.

AFNUM represents companies in the digital industries in France, including providers of artificial intelligence technologies, equipment and services whose tools are now used daily by creative professionals. In this regard, she welcomed the Commission’s initiative and the ambition of a comprehensive strategic vision, articulated with the AI Continent Plan, the Apply AI Strategy and the AI Act.

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POSITIONSPAPIER Positionierung der Kultur- und Kreativwirtschaft in Deutschland zur geplanten EU-Strategie für KI in den Kultur- und Kreativsektoren Kreativität, Wertschöpfung und Wettbewerbsfähigkeit im KI-Zeitalter gemeinsam sichern Berlin, 11.09.2026 Einordnung Die Kultur- und Kreativwirtschaft ist ein zentraler Innovationsmotor Europas und ein Schlüsselsektor für wirtschaftliche Dynamik, gesellschaftliche…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BumaStemra, the Dutch collective management organisation for music authors and publishers, welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors. As a member of GESAC, BumaStemra fully supports GESACs contribution to this Call for Evidence. In our attached contribution, we would like to emphasise several priorities.

Börsenverein des Deutschen Buchhandels e.V. represents the German book sector. We are grateful for this opportunity and would like to provide the following feedback: Any strategy around AI and the creative sectors must ensure that technological innovation and the protection of human creativity are not pitted against each other.

The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to respond to the European Commissions call for evidence for its upcoming artificial intelligence (AI) strategy for the cultural and creative sectors (CCS). We respectfully submit the recommendations set out in the attached document.

Centrum Cyfrowe is pleased to share its submission to the call for evidence. The AI Strategy for the Cultural and Creative Sectors offers a vital opportunity to strengthen the foundation of European digital sovereignty, aligned with the core values outlined in the Article 167 of the Treaty on the Functioning of the European Union, which shall contribute to the flowering of cultures of the Member States, while…

GESAC Contribution to the EC Call for Evidence on the AI Strategy for the Cultural and Creative Sectors September 11, 2026 The European Grouping of Societies of Authors and Composers (GESAC), representing more than 1.2 million creators through 32 authors’ societies across Europe, welcomes the European Commission’s (EC) initiative to develop an AI Strategy for the Cultural and Creative Sectors (CCS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

A future EU AI Strategy for the Cultural and Creative Sectors should, insofar as the film and audiovisual sector is concerned, pursue a clear overarching policy objective: incentivize the creation and production of compelling films and audiovisual works, secure new and skilled jobs, expand the talent pool and upskill existing contributors, whether in creative, technical or business functions.

We consider the initiative to develop a strategy for creating a fair and protected environment in which artificial intelligence can be used responsibly to be an important and welcome step. The strategy acknowledges both the challenges and the opportunities associated with this development.

The European Music Council (EMC) is a non-profit organisation dedicated to the development and promotion of all genres and types of music in Europe with a membership comprised of music organisations involved in the fields of music education, creation, performance, participation, production and heritage. All these areas representing the economic, artistic and social dimension of music are afflicted by AI.

The European Arts & Entertainment Alliance is composed of three global trade union Federations, namely the International Federation of Actors (FIA); The International Federation of Musicians (FIM) and UNI MEI Global Union for Media, Arts and Entertainment. These three Federations bring together the sectoral unions of performers and technical professions in the Media, Arts and Entertainment sector globally.

Contribution to the Call for Evidence on an AI Strategy for the Cultural and Creative Sectors 11 September 2026 Introduction: News Media Europe (NME) is the voice of the progressive news media industry in Europe, representing over 2,700 news brands in print, online, radio and TV, through national associations from thirteen countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached CEPI's submission. CEPI the European Audiovisual Production Association represents over 3000 European independent film and TV producers across Europe through 19 national associations across 17 European countries.

The Danish Rights Alliance welcomes the Commission's initiative to develop an AI Strategy for the Cultural and Creative Sectors. We wish to contribute with concrete evidence from our investigations into the datasets used to train generative AI.

Animation Ireland welcomes the opportunity to contribute to the European Commissions development of an AI Strategy for the Cultural and Creative Sectors (CCS). Artificial intelligence presents significant opportunities for animation and the wider creative industries.

The Production Alliance welcomes the opportunity to submit comments as part of the Call for Evidence on the planned AI Strategy for the Cultural and Creative Sectors. The German production industry is currently grappling with the opportunities and challenges presented by the use of artificial intelligence in film and television production.

SGAE is the Spanish collective management organisation for musical, audiovisual and dramatic works. The main points of our contribution, developed in the attached document, are the following. The Strategy must rest on a functioning framework of authors' rights.

Warner Music Group welcomes the Commissions aims to enhance the resilience, competitiveness, and sustainability of Europes creative economy. Europe's music industry is supported by a clear legislative framework, which is vital to business certainty and local investment. The Commissions aims would be best served by a focus on the implementation and enforcement of that framework.

Gramex is the collective management organization for recorded music in Finland, representing performing artists featured on sound recordings and music producers. We would particularly like to draw attention to the following key issues: The development of AI services should be supported by a balanced and efficient licensing market that benefits both AI operators and the creative sector, while fostering genuine trust…

CALL FOR EVIDENCE AI Strategy for the Cultural and Creative Sectors Initiative Urheberrecht, Deutschland Berlin, 10. September 2026. Die Initiative Urheberrecht vertritt die Interessen von rund 140.000 Urheber:innen und ausübenden Künstler:innen in den Bereichen Komposition, Orchester, Journalismus, Film und Fernsehen, Fotografie, Dokumentarfilm, Belletristik und Sachbuch, Design, Illustration, Bildende Kunst…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The initiative and its guiding principles are extremely ambitious given the rapid development in the field of artificial intelligence and the rather low level of development and strategic application of related tools in the cultural sector (as opposed to creative industries).

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Full Submission attached. The European Publishers Council (EPC), representing leading news media and publishing organisations across Europe, welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors. Press publishing and professional journalism are strategic infrastructure for Europes culture, democracy and AI-driven future.

AI, Culture (consultation) Artificial intelligence strategy for the cultural and creative sectors Call for evidence1 - Feedback period 27 July 2026 - 11 September 2026 (non-legislative initiative) EUROCINEMA’s contribution EUROCINEMA is a Brussels based organization representing audiovisual producers’ organizations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This submission draws directly on key findings and recommendations from the 'AI Art Assembly Report II', published in May 2026 by Beta Festival in partnership with the Research Ireland ADAPT Centre for AI-Driven Digital Content Technology.

This contribution is submitted by HSRT (Hypertech Sustainability Research & Technology Center) on behalf of the HAMLET Horizon Europe consortium (GA No. 101178362). HAMLET (Human-centred generative AI framework for cultural industries digital transition) is a Horizon Europe Innovation Action developing and testing human-centred generative AI with cultural and creative professionals in game development, dance and…

Swedens Writers Union welcomes the European Commissions initiative to develop a dedicated strategy for artificial intelligence (AI) in the cultural and creative sectors. For AI development to be sustainable, the strategy must uphold copyright and safeguard human creativity, cultural production, and the livelihoods of authors and literary translators.

CALL FOR EVIDENCE AI Strategy for the Cultural and Creative Sectors Submission by the European Composer and Songwriter Alliance (ECSA) 11 September 2026 Introduction ECSA welcomes this call for evidence by the European Commission on the forthcoming AI Strategy for the Cultural and Creative Sectors (CCS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

REEVALUATE contribution to the European Commission Call for Evidence AI Strategy for the Cultural and Creative Sectors This contribution is submitted by Hypertech on behalf of the REEVALUATE consortium (GA No. 101132389), which welcomes the European Commissions proposed AI Strategy for the Cultural and Creative Sectors.

Response to European Commission Call for Evidence on Artificial intelligence strategy for the cultural and creative sectors 11 September 2026 n behalf of Chamber of Progress – a tech industry association supporting public O policies to build a more inclusive society in which all people benefit from technological advancements– I write in response to the Call for Evidence on an Artificial intelligence (AI) strategy…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IMPF welcomes the Commissions decision to develop a dedicated AI Strategy for the Cultural and Creative Sectors. The Call for Evidence correctly recognises that AI offers opportunities while also raising particular legal, economic and cultural challenges. For IMPF, the central policy question is therefore not whether Europe should embrace artificial intelligence.

I support the need for an AI strategy for the Cultural and Creative Sectors that is innovative, reciprocal, inclusive and protective of the public interest. As someone working in film heritage, I see this debate up close. Our archives hold irreplaceable moving image collections often fragile, undigitised, and rich with the visual and audiovisual record of Europe's shared past.

TF1 Group, France's leading private broadcaster, welcomes the opportunities offered by artificial intelligence across the audiovisual value chain, while highlighting the need to preserve fair competition, copyright protection and the visibility of European content.

AIE, the music performers collective management organization in Spain, welcomes the Commissions initiative to prepare an EU Strategy for AI in the cultural and creative sectors. AI can support creation, distribution, rights management, discoverability and access to culture.

Trans Europe Halles strongly welcomes and supports this call for evidence as a crucial opportunity to shape a responsible AI strategy for the Cultural and Creative Sectors. In responding to the proposal, we wish to emphasise that the strategy should prioritise the protection of human creativity, uphold the right of artists and cultural organisations not to use AI, establish strong data governance frameworks that…

Generative AI is not and will never be "genuine creation" since it's built on a pool of already finished creations, largely obtained illegally and non-consensually from their creators which are human. That sentence alone should be enough to put heavy regulations around the use of Generative AI and the development of Generative AI.

AI should be treated primarily as a tool for digital visitor engagement, not a content-generation shortcut competing with the artists, curators, and collections it serves. This is the clearest way to ensure AI complements rather than replaces human creativity: it should extend the reach of what curators and artists already make, not generate substitutes for it.

A future EU AI Strategy for the Cultural and Creative Sectors should, insofar as the film and audiovisual sector is concerned, pursue a clear overarching policy objective: incentivize the creation and production of compelling films and audiovisual works, secure new and skilled jobs, expand the talent pool and upskill existing contributors, whether in creative, technical or business functions.

Public Libraries and the AI Strategy for the Cultural and Creative Sectors Public libraries are uniquely positioned to support the AI Strategy for the Cultural and Creative Sectors due to their scale, reach, accessibility and trusted role within communities. The recent OMC report, Strengthening Europe through Public Libraries, identifies public libraries as essential social, cultural and educational infrastructure.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Opinion of the Belgian Professional Federation of Authors, Commonwealth and Illustration (ABDIL): We, the authors, refuse a massive and widespread use of AI in our professional fields. Today, we are warning our partners in the cultural sector who are pushing for the adoption of this technology in our ecosystem, of the devastating effects this will have on our practices, our professions and our lives.

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AI has a negative impact on the art and creative industry. I understand the improvement it entails in mechanical or data management tasks, but that it draws from the gear that does not belong to it, it is theft that is thrown away and, in the end, it is a tool that breaks down all the moral and ethical codes established.

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MAGYAR LAPKIADÓK EGYESÜLETE Hungarian Publishers’ Association www.mle.org.hu Hozzájárulás a kulturális és kreatív ágazatokra vonatkozó mesterséges intelligencia stratégiáról szóló véleményezési felhíváshoz Budapest, 2026. szeptember 11.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Kopiosto supports the initiatives objectives of promoting Europes linguistic and cultural diversity, fostering innovation and strengthening the resilience of the cultural and creative sectors. Kopiosto represents over 100,000 Finnish authors, performers, publishers and other creative sector rightsholders. Effective transparency is a prerequisite for licensing, rights enforcement and fair remuneration.

The National Library of France (Bibliothèque nationale de France - BnF) supports the European Commissions initiative to develop a European strategy for AI in the cultural and creative sectors. The adoption of such a strategy is of particular importance for heritage institutions in view of the transformations brought by generative AI.

LITA welcomes the European Commissions Call for evidence on AI Strategy for the CCS, and supports its ambition to ensure that AI reinforces human creativity, cultural and linguistic diversity, and the sustainability of Europes creative economy. LITA, Society of Authors, is a civic association of authors working in the fields of literature, theatre, audiovisual and fine arts.

Contribution from Creative Skills Week (https://creativeskillsweek.eu) and the Blueprint project CYANOTYPES (https://cyanotypes.website) European AI infrastructure, cultural sovereignty and the capabilities to shape Europes AI future The Creative Skills Week and the CYANOTYPES community welcome the European Commissions intention to develop a dedicated AI Strategy for the Cultural and Creative Sectors (CCS)…

Avant-Garde Lawyers (AGL) is a French NGO whose mission is to ensure that artists can imagine and create freely, without fear of censorship, persecution, or legal challenges, by providing innovative legal strategies that protect the rights of artists around the world.

AI raises significant social and economic challenges, particularly for individual creators. Performers exclusive rights must be respected when their performances are used for AI training, requiring authorization as well as fair remuneration. AI outputs should only qualify for copyright protection where there is creative and determinative human intervention.

In the view of the Dachau Memorial Centre, unregulated AI use risks, inter alia, distorting history (see open letter from the Memorial Centres, 01/2026, https://www.kz-gedenkstaette-dachau.de/nachrichten/offener-brief-konsequentes-vorgehen-gegen-ki-generierte-holocaust-verfaelschungen-auf-social-media-plattformen/). At the same time, AI use offers new opportunities in stockpiling.

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Wie das Sondierungspapier richtig feststellt, bewirken neue Technologien wie KI eine Veränderung des Schaffens, der Bewahrung, Interaktion und Erfahrung von Kunst und Literatur. Der Deutschunterricht und der Erwerb allgemeiner Schreib-, Lese- und Problemlösungskompetenzen in Schulen und Hochschulen müsste in der Strategie stärker berücksichtigt werden, um sicherzustellen, dass auch künftig gesellschaftlich relevante…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UBVA contribution to the Call for Evidence A European Strategy for AI in Science The Danish Committee for the Protection of Scientific and Scholarly Work (UBVA), representing more than 500,000 academics within the Danish Confederation of Professional Associations, welcomes the European Commissions Call for Evidence on a European Strategy for AI in Science.

IAA Europe Submission to the European Commission’s Call for Evidence: “Artificial intelligence strategy for the cultural and creative sectors” The International Association of Art (IAA) Europe, an umbrella organization for visual artists’ associations in Europe, is thankful for the opportunity to contribute to this call for evidence on an artificial intelligence strategy for the cultural and creative sectors in the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AEC welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors. The Commissions proposed principles technology at the service of culture, support for genuine human creation, protection of copyright, cultural and linguistic diversity, inclusion, sustainability and European sovereignty provide a strong basis for the Strategy.

We welcome the European Commission's initiative to develop a dedicated AI strategy for the cultural and creative sectors. For the European film industry, AI offers significant opportunities in localization, distribution, discoverability, audience engagement, and the restoration of film heritage.

We are facing the devastation of Europe’s once thriving cultural and creative landscape caused by non-European manufactured applications that use our works free of charge to ensure that we are squeezed out as the best.

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From our work at the Multimodal Data Fusion and Analytics Group (M4D) of ITI-CERTH, bringing together AI, cultural heritage and interactive experiences, we see a clear need for closer collaboration between technology developers and cultural professionals. Through projects such as i-Game, Mindspaces, ReSilence etc.

VAUNET welcomes the European Commissions planned AI Strategy for the Cultural and Creative Sectors. AI offers significant opportunities for private media companies to innovate, increase efficiency and develop new services. At the same time, it is fundamentally changing the conditions for production, distribution, rights management, market access and the refinancing of professional media content.

The Motion Picture Association is a trade association representing seven international producers and distributors of film and television content, which serves as the global voice and advocate of the international film, television, and streaming industry.

Mr LAdami welcomed the European Commission’s initiative to launch this call for evidence on the AI strategy for the cultural and creative sectors. As a collective management organisation (CMO) for the related rights of performers in the audiovisual and audio sector, Adami has already recognised the reality of the challenges posed by AI.

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Generative AI is an unnecessary and invasive tool that, contrary to aiding or favouring, acts to the detriment of any creative and cultural activity. Beyond its overall negative consequences (energy spending and environmental damage, propaganda generation, fake news, and deepfakes, cognitive impact, etc.), AI severely impacts the creative sector, which is the specific topic of this initiative.

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Koda is the Danish collective management organisation (CMO) for songwriters, composers and music publishers, representing more than 53,000 members and rightsholders. Koda welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors. Please find attached Kodas contribution to this Call for Evidence.

The Institute of Translation and Interpreting (ITI) welcomes the Commission's recognition that AI should complement rather than replace human creativity, and that cultural and linguistic diversity must sit at the centre of this strategy.

The use of generative AI must be accompanied by a system of safeguards, protection of fundamental rights and authorship that does not exist. Its functioning is currently governed by appropriationism and the autonomous reinterpretation of the work of illustrators, cartoonists, scriptwriters, etc.

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Thank you. Thank you very much for the opportunity to participate. We refer to our attached statement (in German). Please refer to our comments (pdf/attached). Authors Rights Initiative [email removed] | www.urheber.info | Köthener Straße 44/2nd floor | D-10963 Berlin Tel: [phone removed]

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The use of AI, especially generative AI, is of concern to me in many respects; as a woman, mother and teacher. A huge amount of data is being used to train AI; in many cases, stolen data does not under any circumstances benefit the original creator. On the other hand, your answers are strong, when they are wrong and make you unreliable. Wikipedia, no; but ChatGPT, if? It does not seem logical.

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The Spitzenorganisation der Filmwirtschaft e.V. (SPIO) is the umbrella organisation representing the interests of the German film industry in the sectors of film production, film distribution, cinema and audiovisual media.

PORTAL STATEMENT We write as practitioners with an unusual credential in this consultation: evidence that the future the Commission seeks was once built. In 1997, a community-owned cable cooperative in Palo Alto, California hosted the world's first digital twin of a real community.

Based on the TEXTaiLES project experiences so far, the following suggestions maybe considered by the strategy: 1. fund shared or subsidised compute infrastructure specifically for Cultural Heritage AI work, since GPU-scale resources are unaffordable for most individual institutions, especially museums;2.

The Association of German Spokespersons is a member of the Copyright Initiative. We agree with the statement of the Copyright Initiative and would like to stress that compliance with all applicable rights, and in particular the GDPR, is an absolute prerequisite for future democratic coexistence.

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Wiley Government Affairs and Public Policy, Europe Call for Evidence: AI Strategy for the Cultural and Creative Sectors Submission by Wiley — September 2026 1. Introduction Wiley welcomes the opportunity to contribute to this Call for Evidence on the forthcoming AI Strategy for the Cultural and Creative Sectors (CCS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

— The EU should enshrine the preservation of human creativity as an objective of its AI and cultural policies. — The EU should enshrine the preservation of cultural diversity as an objective of its AI and cultural policies. — Human creativity must remain visible and detectable in relation to the mass production of AI content.

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Konsultation: EU-Strategie für KI in Kultur- und Kreativbranchen Stellungnahme der Illustratoren Organisation (IO) – Frankfurt a. M., 11.9.2026 Die Illustratoren Organisation e.V. (IO) ist der Berufsverband für Illustrator:innen in Deutschland und vertritt die politischen, wirtschaftlichen und künstlerischen Interessen ihrer rund 3.000 Mitglieder aus allen Bereichen der professionellen Illustration.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

For us from the Deutsche Komponist:Innenverband e.V. (DKV), it is important for human composing and music creation to stand before AI music production. If music is used for learning, this must at least be compensated and distributed collectively through collecting societies. When making music with AI, composers must be compensated as if the music had been made exclusively humanely.

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As a foundation of Lower Saxony memorial sites and memorial site of Bergen-Belsen, we are currently witnessing an increase in AI-generated Holocaust-related content, especially on social media. We therefore need clear and strict rules on the use of artificial intelligence, as well as a general obligation to flag AI-generated content.

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I am a publisher. For almost 20 years I have seen the living conditions of workers in the publishing sector deteriorating due to a lack of support and a legislative framework, but in recent years the situation has become precarious due to the proliferation of so-called generative artificial intelligence, of which I am radically against.

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Call for Evidence, NDP Nieuwsmedia Contribution to the Call for Evidence on AI Strategy for the Cultural and Creative Sectors 10 september 2026 Introduction: NDP Nieuwsmedia is the trade organisation for Dutch news publishers, representing 95% of the privately owned news media companies in the Netherlands. Since the launch of ChatGPT we monitor the disruptive and possibly existential impact of AI on the news sector.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COMMUNIA welcomes the ambition of this initiative. An overarching strategic vision for AI in the cultural and creative sectors is needed to guide and complement ongoing legislative and regulatory processes and to shape EU support for these sectors as they navigate the transition brought about by AI.

IFRRO welcomes the European Commissions Call for Evidence on AI Strategy for the CCS and supports its aim to ensure that AI reinforces human creativity, cultural and linguistic diversity, and the sustainability of Europes creative economy. IFRRO supports the collective management of reproduction and other rights in text- and image-based works through a network of RROs of over 160 members.

As the only federation worldwide representing the interests of authors of the book sector, the European Writers Council (EWC) is a non-profit, non-governmental federation constituted by 55 writers and literary translators associations in 34 European countries, from the EU, the EEA countries Iceland and Norway, as well as Belarus, Switzerland, Montenegro, North Macedonia, and the UK.

The European Cultural and Creative Industries Alliance (ECCIA) considers the European Commissions forthcoming AI Strategy for the Cultural and Creative Sectors a timely and important opportunity to ensure that artificial intelligence supports rather than undermines Europes creative excellence, cultural heritage and industrial competitiveness.

AI Assemble welcomes the European Commissions initiative to develop a dedicated AI strategy for the cultural and creative sectors. Europe has an opportunity to build a model in which AI strengthens human creativity, cultural diversity and competitiveness while preserving the rights, agency and livelihoods of creators. The strategy should be guided by five priorities.

TikTok is a leading global video-sharing platform. Creators of all backgrounds sit at the heart of TikTok, forming a community where authenticity and diversity are celebrated. With more than 200 million monthly active users across Europe, our top priority is to promote a safe experience so that everyone can express their creativity.

CEATL is Europes largest organisation of literary translators with 38 member associations in 30 countries. We took part in the AI Office Code of Practice consultation and in the workshop on the Identification of Machine-Readable Protocols for Expressing Rights Reservations and welcome this Call. Literary translation is essential to the circulation of world literature and the distribution of ideas.

Artificial intelligence is becoming a key driver of innovation and growth in Europe’s creative industries. Their potential lies not only in the development of new technologies, but above all in their successful application along creative value creation processes.

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The International Federation of Library Associations and Institutions represents the 3 million libraries of all types, across Europe and around the world. We administer the Knowledge Rights 21 programme, which works to ensure that the voice of researchers, educators, readers and the libraries that they rely on is heard in policy-making.

It's not the use of AI that causes problems, it's its abuse. It has been intended to replace people's work fully or mostly (and this even though it is does not offer the same level of quality and accuracy). As a result, people are paid half or less the money they earned before - or have lost their job, regardless of how long they'd been doing it.

Danish Press Publications Collective Management Organisation - DPCMO Ref. Ares(2026)8639655 - 11/09/2026 Introduction – the Data Asymmetry DPCMO is aware of the strong contributions submitted to this Call for Evidence by News Media Europe, EMMA/ENPA and IFRRO.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

If I feel that AI has made us a collective evil where we no longer have a good imagination or something that is really genuine, whether on social media, we only see the same advertising taken from someone that if we take the work of doing work from scratch, the rubbish entertainment on apps such as TikTok and Instagram and others, is burning CADE, but we see more AI videos that have the same content, rather than…

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Artificial intelligence should be regulated. Its use has a direct and catastrophic impact on humans and the planet, with the millions of wonderful species with whom we share it. No other species harms the planet like us, but they are the ones who suffer the most. And we, as a species we bring very little to the planet...

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As this is my view on AI, I would like to insult but it is not possible that I will only tell what I have to say, this technology has created many problems, not only for artists of all kinds but also for people in real life, such as photos of women and minors being edited with AI in a suggestive way, the notorious environmental impact of water and electricity consumption, the provocation of a lack of employment for…

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Artificial intelligence is a tool that makes life easier for humans in many ways. Not needed anymore. AI is a great technological advance that helps us move forward as a society in areas such as medicine, health, well-being, etc. AI also helps optimise jobs and time. On the other hand, AI is a double-edged weapon.

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Artificial intelligence is a terrible threat at all levels to all those who have a job in the field of, or carry out any artistic or creative activity. Sunshine has proven not to be environmentally sustainable, but has become a real visual poisoning for any internet user.

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Contribution from an independent audiovisual producer: documentation of AI use as the missing layer I am an independent film producer based in Warsaw with over twenty years of experience, mostly on projects where new technologies serve storytelling, and I teach production at two Polish film schools. I write from production practice, not from research. The gap I see every day is not a shortage of AI tools.

Generative content with Artificial Intelligence such as duplicated images, videos and voices is frightening in several senses for people: it can be used with malicious intent such as creating false evidence, scams, harassment and theft of intellectual and creative property. AI was planted without people’s permission, has no limits, and its dangers are present in AHORA.

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Let’s live without AI! This has always been the case. They want to take away our ability to think, our creativity, imagination, critical thinking. And not only that, they also want to take away water, the habitat of animals, plants, trees, our health. AI leads to thousands of losses and affects ALL of us. What will happen to future generations? If water is lost, life is lost.

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Català: Siguent the Catalan national target ‘aprofito per reclaim també’ included the Catalan llengua dins de l’Administració Europea! DIT això, on AI. Mon col· lapsarà amb as much cursa per veure qui la té més grossa. Ja està bé, fem un ÚS coherent dels recursos i recordem que som humans.

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This response draws upon the expertise of researchers, creative practitioners and creative industries leadership from the BRAID project, reflecting the views of the authors as well as key research undertaken by the wider BRAID network. BRAID (Bridging Responsible AI Divides) is an £18m UK initiative to embed Arts and Humanities research into the responsible AI ecosystem.

The protection of intellectual property and copyright must be protected and must be a top priority. Illustrators in particular face an existential threat. Their individual artistic styles, which have been laboriously developed over the years, are massively uploaded, analysed and copied into AI models without consent.

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Dansk Filmklipperselskab (DFKS, Society of Danish Film Editors) is the professional organisation for professional film clippers in Denmark. We thank you for the opportunity to contribute to the Commission’s Call for Evidence on an AI strategy for the cultural and creative sectors. We welcome the initiative and support that AI must complement not replace human creativity.

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I'm a "young" visual artist, young enough to have had some digital artistic training combined with the more classical ways, analog methods. Since Generative AI exploded, it has only created harm, and IT IS harm: we all know that it's thanks to the theft of millions of copyrighted images and human intellect that the generative AI came to life and we creative EU citizens expect a critical approach from you.

This technology is not another tool. It is not only making our profession even more precarious, but it also operates under the unauthorised misuse of the works of millions of artists. The generative AI business model is fraudulent and immoral and should have no place in our work process alongside other technological tools that are lawful and facilitate our creative process, such as graphics tablets.

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I believe that AI should not create creative projects from the outset, or create arted.Creativity is a human ability and if humans take away that ability, because we become comfortable and everyone if we ask AI, we will stop thinking, and if we stop thinking, we will again be useless and dependent on an IT system and databases.

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The Spanish Association for Audiovisual Translators and Adapters, a member of Audiovisual Translators Europe, welcomes the opportunity to express their absolute opposition to the use of GenAI in the cultural and creative sectors and industries. A strategy or policy that will benefit culture in general and the European sector in particular, as well as citizens is not possible with GenAI.

I speak as someone who has previously directly worked in the field of making AI models and who very closely knows how they work. Partly of how the AI was being used and marketted I transitioned to working in creative industries. So I say it from my personal experience that the use of Generative AI in cultural and creative sectors is highly detrimental to say the least.

SIREH fully endorses the response submitted by Europa Nostra as leader of the European Heritage Hub, and the 3 priorities set out by Europeana: innovate, protect and empower. We support an AI Strategy grounded in trust, openness, reciprocity and the public interest, and a holistic understanding of heritage in its tangible, intangible and digital dimensions.

AI is destroying jobs in the creative sector at a fast pace. Leaving no options to learn new talents and young creative people who start their careers now because their work is now superfluous with AI. The simpler and more mechanical jobs given to the people who started have been replaced by AI.

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AVÜ e.V. is the professional association for audiovisual translation and language editing translation for subtitles, dubbing, voiceovers, screenplays and video games, as well as accessible language editing (subtitles for the hard of hearing, audio description) in the German-speaking area.

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The CARD welcomes the Commission’s initiative to gather stakeholders’ feedback on its upcoming AI Strategy for the Cultural and Creative Sectors. In this context, it wishes to formulate a clear and unambiguous position. As a preliminary point, the CARD wishes to emphasise a key principle: artificial intelligence must remain at the service of human creativity, without replacing or harming the work of authors.

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I believe that Artificial Intelligence can be a double-edged weapon in acuality. What do I mean? I see Artificial Intelligence as a very good support tool. Whether for those who need to write a book, draw a comic, or some other creative project; because in order to do so one needs to be informed.

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I believe that the use of AI should be banned in some areas when it comes to public affairs because of the problems it poses for some social groups, encouraging discrimination. For example, I have seen a multitude of municipalities, civic centres and other public bodies create and publish, officially, AI-made posters that completely break several fundamental rules of graphic design.

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IMRO Submission to European Commission Call for Evidence for the AI Strategy for the Cultural and Creative Sectors September 11, 2026 The Irish Music Rights Organisation (IMRO), Ireland’s national collective management organisation for songwriters, composers and music publishers, welcomes the European Commission’s initiative to develop an AI Strategy for the Cultural and Creative Sectors (CCS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a translator, under a geopolitical point of view, I think EU has to have its own AI system(s) regardless of US and non-EU States willingness to provide their own systems. However, under a day-to-day work point of view, in my experience, AI, and machine translation, has a detrimental impact on tasks where attention to details is key because it tends to provide a high sense of confidence hiding the small but…

The Alliance of German Designers (AGD) welcomes the European Commission’s initiative to develop an autonomous AI strategy for the cultural and creative sectors. Design is at the crossroads of culture, business and technology. Designers use AI as a tool while experiencing how generative systems transform markets, value creation, and professional roles.

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A working group was set up in February 2026 within the Higher Council for Culture of the Wallonia-Brussels Federation. This group brings together the various consultation chambers of the Belgian French-speaking cultural sector, each chamber representing a cultural and creative sector supported by the Fédération Wallonie-Bruxlles (Audiovisual & Cinéma, Letters & Livres, Living Arts, Music, Plastic Arts, Heritage…

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AudioVisual Translators Europe (AVTE) is the umbrella organisation of European associations representing subtitlers, dubbing translators and adaptors, voice over translators, video game translators, screenplay translators and audio description authors. The hereby attached AI statement is presenting our stance on the challenges and risks of AI for our profession.

Getty Images’s response to the Call for Evidence on the Artificial intelligence strategy for the Cultural and Creative Sectors Getty Images welcomes the European Commission's initiative to develop an AI Strategy for the Cultural and Creative Sectors (CCS). We support the Strategy's core principle that AI should complement, not replace, human creativity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Choirfarm Ltd is a UK technology SME building AI tools for the live performance sector. Over four months we convened a consortium of twelve organisations across seven countries to design a European programme on AI in live performance work practice: three universities, a research foundation, cultural organisations, four technology SMEs, and Pearle* Live Performance Europe.

BZDV - Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP - Medienverband der freien Presse e. V. Comments on the Call for Evidence – Artificial intelligence strategy for the cultural and creative sectors 8 September 2026 Our feedback will address four dimensions of key relevance for press publishers, which should be fully reflected in the Strategy, namely (i) safeguarding the role of the free press in…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Magazine Media Association (EMMA) and the European Newspaper Publishers Association (ENPA), representing the vast majority of European publishers of newspapers, magazines, periodicals and specialised press, including in digital, appreciate this opportunity to provide its feedback on this Call for evidence, submitted via the document in annex.

Invito a presentare contributi della Commissione europea per una strategia per l'IA nei settori culturali e creativi 10 settembre 2026 La diffusione dell'intelligenza artificiale sta modificando in profondità le modalità con cui i contenuti culturali vengono ideati, prodotti, distribuiti, promossi, conservati e fruiti.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of the French Publishers Association, we would like to share the following feedback. Artificial Intelligence (AI) is already a reality, with visible impact on the market and in publishers practices. On the one hand, publishers have faced a flood of unlabelled fully AI-generated books, sometimes even using the name of existing authors, which unfairly compete with real books, mislead consumers and undermine…

Hand for Handmade Foundation works with artisans and handmade enterprises across India. Our training pilots show that AI can support product descriptions, photography, catalogues, communication, cultural documentation, and market access. However, access must include Indian languages, voice use, simple mobile tools, local guidance, and time to practise.

The fact that you mention the usage of AI and genuine creation in one sentence shows everything to me - you have absolutely no clue what you are talking about. Theres no unique or genuine creation with the use of AI tools. Its always plagiarism. The companies behind AI stole from the creative industries for years to train there LLMs. Every creative thing, AI is generating, is the result of exploitation.

APORTACIÓN DE PATE A LA CONSULTA PÚBLICA SOBRE LA ESTRATEGIA DE IA PARA LOS SECTORES CULTURALES Y CREATIVOS 1. Representatividad e interés de PATE PATE representa los intereses de productores audiovisuales españoles que desarrollan, financian y organizan la creación de obras, asumiendo el riesgo empresarial y articulando su explotación. 2.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ref. International Ares(2026)8623351 Copyright Media - 10/09/2026 Stellungnahme der Corint Media im Rahmen der öffentlichen Konsultation der Europäischen Kommission zu einer KI-Strategie für die Kultur- und Kreativbranchen (Ref.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BONO supports and welcomes the initative to build an AI strategy for the cultural and creative industries, and the opportunity to provide a response to the call for evidence. BONO is the Norwegian Visual Artists Copyright Society, representing more than 3 000 Norwegian artists, and 150 000 artists from all over the world in Norway.

Response from Europa Nostra, as leader of the European Heritage Hub and coordinator of the European Heritage Alliance In line with the contribution submitted by the Europeana Initiative to the European Commissions Call for Evidence and its vision of Public AI, Europa Nostra fully supports an AI Strategy grounded in trust, openness, reciprocity, public values and the public interest.

Mr LaScam thanked the European Commission for organising this call for evidence on the future AI strategy for the cultural and creative sectors. LaScam is a French collective management organisation representing almost 59 000 authors and authors of documentary, journalism, photography, podcast and writing.

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I'm writing as a self-employed business from Poland, whose significant part of the income comes from selling art and products with my designs on them, as well as an EU citizen concerned for my environment, vulnerable parents and community. AI is creating several issues, which I'm hoping EU regulations to remedy.

Kunsten 92 is the Dutch advocacy organisation for the arts, culture, heritage and creative sectors. We welcome the European Commissions initiative to develop a dedicated AI Strategy for the Cultural and Creative Sectors. We suggest the following: 1. The CCS active role in shaping AI The CCS are not only users of AI but are vital to its development.

ITI - the Information Technology Industry Council - is the global trade association of the technology industry, representing 80 of the worlds most innovative tech companies. Our membership spans across the entire spectrum of technology, including global leaders on software and AI, hardware, cloud, cybersecurity and semiconductors.

The International Federation of Film Distributors and Publishers Associations (FIAD) welcomes the European Commissions ambition to develop a dedicated AI Strategy for the Cultural and Creative Sectors (CCS). FIAD gathers national organisations of film distribution companies.

The Association of Professional Photographers (APF), Bulgaria, presents its opinion on the European Commission’s call for evidence on the Strategy for Artificial Intelligence in the Cultural and Creative Sector.

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The Commission should base its AI strategy on the protection of image creators’ rights. It is therefore recommended that the following priorities be taken into account in the strategy: Legal certainty on the application of the existing copyright framework. The meaning of the terms used and the conditions under which a TDM right reservation can be made are unclear.

Filed in Dutch · English published by the European Commission

European Visual Artists (EVA) welcomes the opportunity to bring the visual artists perspective to the development of a future strategy for AI in the Culture and Creative Sector, in the context of the Culture Compass for Europe.

From the perspective of regional and minority languages, AI and its impact on cultural and creative sectors is a huge discussion point. We at the European Centre for Minority Issues currently lead the PLURILINGMEDIA COST Action (www.plurilingmedia.eu), focusing on regional and minority languages in media.

Czech Television welcomes the preparation of a European strategy for AI in the cultural, creative and media sectors. As a public service media organisation, audiovisual producer, news provider, archive institution, operator of digital and educational services, and EBU member, Czech Television recognises AIs opportunities and risks throughout the content value chain.

AI currently devalues artistic work. All life, artistic work has been done less because it is difficult to assess objectively, and everyone’s thoughts are already in the spotlight. But since AI is there, this has intensified, because in a few minutes you are making a proposal. In addition, at the level of content.

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UNIC’s response to the Call for evidence of the “Artificial intelligence strategy for the cultural and creative sectors” The International Union of Cinemas (UNIC) represents cinema trade associations and key operators across 39 European territories. In the EU alone, UNIC members represent around 28,500 screens, accounting for 603.6 million admissions and €4.9 billion in box office revenues in 2025.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Teosto, the Finnish Composers Copyright Society, a collective management organisation representing composers, lyricists, arrangers and music publishers in Finland welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors.

The Danish Chamber of Commerce welcomes the initiative and supports the ambition to create a fair and sustainable interaction between AI and the cultural and creative sectors. AI holds great potential for cultural and creative industries and can contribute to innovation, new business models and access to new markets and customer groups.

Filed in Danish · English published by the European Commission

REMA welcomes the European Commissions initiative to develop a dedicated AI strategy for the cultural and creative sectors. Our network brings together more than 210 organisations across Europe, working with over a thousand years of musical repertoire.

PILEn, Partenariat interprofessionnel du livre et de l’édition, carried out a study on the subject, the results of which were presented in December 2026. This can be found in the attachment. This study attempted to measure the impact of AI on the various professions in the book ecosystem, grouped into 4 main clusters.

Filed in French · English published by the European Commission

AI is killing creativity. As a computer game developer, I have made a lot of games reflecting our culture, our society and depicting the complex pieces of our deepest emotions, memories and life experience. Even if generative AI is only used for parts of this, a lot gets lost in between. The chaos of the human experience, the imprecision of who we are, the emotional resonancy of moments we can experience in games.

De Creatieve Coalitie represents 40,000 workers in the Netherlands cultural and creative sectors. We welcome the Commissions commitment that AI should complement human creativity. This requires rights, fair pay and incentives that sustain creative livelihoods.

AIPIA, the Italian Association of Professionals in Artificial Intelligence, proposes that the European strategy for AI in the cultural and creative sectors link innovation, professional skills, protection of human creation and linguistic diversity.

Filed in Italian · English published by the European Commission

I am writing to you to express my feelings against generative AI and the horrible future we are creating with it, as an artist I am very perverted, it is very possible that hundreds of works I have created have already been stolen and fed into generative AI and I cannot do anything because big companies are profiting.

Filed in Spanish · English published by the European Commission

ZAPA welcomes the European Commissions initiative to develop an AI Strategy for the Cultural and Creative Sectors and underlines that the deployment of artificial intelligence in these sectors should be based on respect for copyright and related rights, transparency, fair remuneration and the sustainable development of human creativity.

The Commission is right to place cultural and linguistic diversity, human creativity and the sustainability of the cultural and creative sectors at the centre of its proposed AI Strategy. The Call for Evidence explicitly recognises risks including pressure on creative jobs, the dominance of mainstream languages, insufficient diversity in training data and threats to the discoverability of European cultural content.

As an active musician, creator and member of Prague based music band Black Holes, I welcome the European Commission's initiative to draft the AI Strategy for the Cultural and Creative Sectors. While much of the current debate focuses on generative AI and copyright, a critical and underutilized potential of AI lies in radically reducing the administrative and operational burden that currently distracts artists from…

The game Association of the German Games Industry welcomes the preparation of an EU strategy on Artificial Intelligence in the cultural and creative sectors. Artificial intelligence is already transforming the way cultural works are created, funded, produced, localised, distributed, found and experienced.

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AI started to become fashionable when I was finishing my studies, I have an advanced 3D animation cycle. I have never been able to find work for myself because of the maldite AI, I have been fighting it for 5 years and looking for work related to the artistic sextor, but it is easier for companies to resort to AI rather than hire an artist to do a work that is moderately decent for them.

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Creative Industries Austria welcomes the European Commissions initiative to develop a dedicated AI Strategy for the Cultural and Creative Sectors. The strategy should ensure that AI strengthens human creativity, innovation, entrepreneurship, cultural diversity and Europes long-term competitiveness while safeguarding copyright, fair remuneration and economic sovereignty.

On behalf of the Federation of European Publishers (FEP) we would like to share the following feedback. Artificial Intelligence (AI) is already a reality, with visible impact on the market and in publishers practices.

In June 2026 the Dutch Council for Culture published the advisory report: Artistic over artificial. Towards a value-driven approach to AI cultural and creative sector. In this report we state that Generative AI is a social and cultural technology. It exists by the grace of cultural data and deeply influences our culture: how we speak, how we think, how we work, what we make and who receives what information.

Pictoright welcomes the Commission’s initiative to develop an AI strategy for the cultural and creative sectors. We support the core idea that AI should complement human creativity and not replace it. The protection of the rights of image creators should be the starting point. Nevertheless, we note that current practice does not provide sufficient guidance in this regard.

Filed in Dutch · English published by the European Commission