Europe’s creative sectors now wait on a strategy that has not yet been written. The Commission closed its call for evidence on an artificial intelligence strategy for the cultural and creative sectors on 11 September 2026, and what arrives next will decide whether musicians, translators, illustrators and film crews treat generative models as a tool or as a competitor with state backing.
The exercise descends from the Culture Compass for Europe, the framework the Commission launched in November 2025 with twenty flagship actions. The compass treated culture as strategic infrastructure rather than decoration, and an AI strategy was one of the promised follow-ups. The call for evidence set out three ambitions: that AI complements rather than replaces human creativity, that it widens access to culture and knowledge, and that it supports a fair and competitive creative economy.
Those three ambitions pull against each other, and the consultation does not hide it. Widening access usually means making cultural works easier to ingest and reuse. Protecting creators usually means making ingestion harder, or at least more expensive. A strategy that promises both will have to choose a side somewhere in the detail, most likely in how it treats the text and data mining exception that underpins much European model training.
That exception, written into the 2019 copyright directive, allows mining of lawfully accessible works unless rightsholders reserve their rights. The reservation mechanism has proved close to unworkable at scale. Individual authors cannot police thousands of crawlers, and collecting societies have limited standing to reserve on their behalf. Creative industries have spent two years asking for a workable opt-out register, and the AI strategy is the obvious place to answer them.
The AI Act supplies part of the answer already. General-purpose model providers must publish a sufficiently detailed summary of training content and put a copyright policy in place, obligations that began applying in August 2025. Enforcement remains thin, and the summaries published so far describe categories of data rather than identifiable works. A transparency duty that cannot be audited gives a songwriter no practical route to discover whether a catalogue was used.
Remuneration is the harder question, and the Commission has so far avoided it. Several member states, France and Germany among them, have national debates running on collective licensing for AI training. A European strategy that leaves licensing entirely to national law will fragment the market it claims to protect. One that proposes a Union-wide mechanism will meet resistance from model developers and from governments courting them.
Access carries its own tension. Cultural heritage institutions want to use AI for cataloguing, restoration and translation, and many hold collections whose rights status is murky. Digitisation projects stall on orphan works and on uncertainty about what a machine may read. Those institutions are the natural constituency for a permissive strategy, and they sit uneasily alongside the authors’ organisations demanding limits.
Smaller languages have a concrete stake. Models trained overwhelmingly on English produce weaker output in Maltese, Latvian or Slovene, and translation subsidies have not closed the gap. The Commission has flagged linguistic diversity repeatedly, most recently in the call for evidence itself, without saying who pays to build corpora for languages with small commercial markets.
Analysts tracking the file, including coverage of the Culture Compass launch, read the strategy as a test of whether cultural policy can constrain digital policy rather than follow it. The creative sectors employ millions across the Union and contribute a larger share of output than most ministers assume.
Consultation responses will not be published immediately, and the strategy itself has no confirmed date. Creators watching the file should judge it by one question when it lands: does it give an individual author a mechanism that works without a lawyer. Everything else in the document will be commentary on that.
