Response to the AI Strategy for the Cultural and Creative Sectors

Introduction

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 think-and-do tank supporting decision-makers in responsibly governing rapid technological change in the interests of current and future generations.

The call sets two clear orientations for the strategy. AI should complement rather than replace human creativity and agency, and it should facilitate progress and broader access to culture and knowledge in the process. CFG supports both orientations. The strategy now needs a practical way to distinguish complementarity from substitution: increases in output, speed, or uptake do not show whether AI is supporting human creative agency, broadening cultural expression, or progressively narrowing both.

CFG’s work on cognitive integrity offers a framework for making this distinction. Cognitive integrity concerns people’s ability to develop, exercise, and autonomously engage the cognitive capacities essential to human work and creative process — critical thinking, decision-making, attention, and learning. These capacities are part of the infrastructure through which culture is created, interpreted, and renewed.

Our contribution is complementary to the parallel review of the Copyright in the Digital Single Market Directive. Licensing and remuneration are essential to a fair creative economy, but they do not address how AI changes the exercise and development of human creative capacities. This response therefore considers AI’s effects at three connected levels: how it affects people’s creative capacities, the quality of their outputs, and the cultural environment through which content is distributed.

1. Preserve and augment the capacities on which human creativity depends

The cultural and creative sectors depend on human judgment, critical reflection, originality, and continuous learning. A strategy that pursues competitiveness through rapid AI uptake without regard to its effects on these capacities risks trading a short-term efficiency gain for a longer-term one: European firms adopting AI have seen labour productivity rise by around 4%, but these gains concentrate in medium and large firms and depend on complementary investment in training, not on AI use alone^[1]. Read against that finding, competitiveness in the AI era looks less like a race to adopt and more like a question of what kind of adoption pays off.

That question is now being asked well beyond the cultural sector. Recent policy and research work has begun describing cognitive capacity itself as an economic asset —  “brain economy” or “brain capital,” built from brain health and brain skills, that determines competitive advantage as AI reshapes work^[2]. Applied specifically to the EU, reviving European competitiveness requires investing directly in brain skills, not only in AI infrastructure^[3]. The cultural and creative sectors are where this argument becomes concrete: creativity, sustained attention, and critical thinking are their productive base. Competitiveness will therefore depend on structuring “human-AI hybrid intelligence” so that AI contributes speed, scale and computational capacity while people continue to exercise judgement, contextual understanding, originality and responsibility. A strategy that grows CCS output while eroding the human side of that collaboration is not, on these terms, a competitiveness strategy at all.

Early research illustrates the risk directly. In a controlled study, participants who delegated their creative work to AI assistants showed weaker neural connectivity, weaker recall of their own work, and the lowest sense of ownership over what they had produced, compared to those unaided ^[4]. Other studies suggest similar impacts on skill development when work is completely delegated to the AI assistant^[5]. However this literature is still emerging, confined to laboratory tasks and focused on short-term effects. This uncertainty is itself a reason to fund research into human–AI interaction alongside support for AI uptake.

This question is especially pressing for people who are still developing professional and creative expertise. In 2025, 63.8% of 16–24-year-olds in the EU used generative AI, including 39.3% for formal education — roughly four times the rate of the general population^[6]. Young people are encountering these tools while still acquiring the capacities their later creative work will depend on, and the EU currently has no strategy for how that encounter should happen, which risks a fragmented response.

The responses emerging outside the EU show how differently this can go. New York City’s public school system, the largest in the US, has just introduced a one-year moratorium on generative AI tools for its roughly 600,000 students up to eighth grade, arguing that “children need teachers and human connection in order to learn and grow”^[7]. China’s Ministry of Education has taken the opposite path, mandating AI integration across every stage of basic education as part of a plan to build “an AI education system with vertical continuity and horizontal connectivity” by 2030^[8]. The EU does not need to choose between one of these approaches — but without a coordinated approach, individual member states and their educational institutions will make this choice unevenly: some children will be exposed to unmediated AI use before the capacities to use it well are formed, while others will forfeit the benefits of AI-assisted learning altogether. As argued in CFG’s submission to the EU Intergenerational Fairness Strategy: future generations must be protected from the risks AI may pose to human agency, but also from restrictive frameworks that deny learners the capabilities and benefits these technologies could provide.

2. Protect and promote the diversity of creative output and its discoverability

The risk of displacing human agency in creative processes has stakes beyond the individual.  Access to generative AI can improve a person’s own creative output while reducing the collective diversity of what a population produces together^[9]. For example, in AI-assisted writing this is showing up as a shift toward Western stylistic norms and a loss of cultural nuance, with the effect strongest for people from cultural backgrounds least represented in training data^[10].

This is compounded by how such content circulates once produced. AI-generated material already makes up a significant share of what people encounter online and its visibility is governed by recommender systems optimised for engagement. The Commission’s own commissioned research reaches the same conclusion from the supply side: discoverability, not availability, is now the binding constraint on which European cultural works reach an audience at all^[11]. Recommender systems built to maximise engagement will tend to surface what performs well on that metric, not based on merit or authenticity. This affects not only what audiences see, but also how creators respond over time to what the system rewards, potentially constraining their own expressiveness and creative processes.

Our commitment moving forward

CFG’s cognitive integrity work — including the framework summarised here and its companion pieces — is offered as a resource for the stakeholder workshops and targeted survey that follow this call. We would welcome the opportunity to contribute further as the strategy develops.

Please contact Lara Natale (info@cfg.eu) at the Centre for Future Generations with any questions or to request further briefing.