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Eurocities response to the European Commission call for evidence.

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 shifts affecting creative workers.

Local governments are key drivers of designing and implementing digital transformation in cities. Recent rapid technological changes have brought both benefits and challenges to cities and society. The EU Digital Agenda sets actions to advance the digital transformation in Europe’s cities. Achieving digital transformation goes beyond local competences; it requires higher ambitions and investments, and bold coordinated efforts at all levels of governance.

How are cities currently using AI for their cultural and creative sector?

For cultural policy and decision making

Rather than delegating policy creation to AI, municipal culture departments can use AI for predictive modelling, demographic insights, and impact assessments such as:

• Crowd and visitor analytics: local administrations use AI-driven sensors and computer vision to analyse foot traffic, museum queue times and public square density during cultural festivals. This data informs crowd control, public safety, and urban noise management policies.
• Public consultations: local administrations use Natural Language Processing (NLP) to process feedback from public surveys and community consultations on what residents want from local cultural funds.
•  Funding and grant management: algorithms assist in organising and preliminary screening of grant submissions (such as checking eligibility), though human panels evaluate creative merit.

To plan and run cultural activities

In event planning and day-to-day cultural programming, cities can use AI to improve logistical efficiency and audience outreach such as:

• Event logistics: Municipalities process historical weather data, public transport schedules and city event calendars with machine learning to optimize event locations, staffing, emergency routes, and public transit schedules. The city of Bologna uses urban digital twins for heritage preservation and sustainable event management.
• Smart cultural tourism: Municipal tourism and culture boards deploy AI-powered chatbots and recommendation systems (for example in Helsinki or Florence) that suggest personalised cultural itineraries, helping disperse tourists away from hyper-congested landmarks to neighbourhood cultural hubs.
• Archiving and digitising: City libraries, local history archives and municipal museums use AI image-recognition and transcription tools to quickly digitise millions of historical artefacts.

Why cities remain cautious on using AI for the cultural and creative sector

European cities currently approach AI in culture in a cautious way due to three main reasons:

• Strict EU regulation and ethics: The EU AI Act and GDPR regulation impose high standards on public sector automated decision-making. Cities like Barcelona, Helsinki and Amsterdam maintain public algorithm registers to disclose every municipal algorithm to citizens.
• Preserving a vibrant local creative community: Local authorities are supporting local artists and creators and are trying to mitigate risks such as copyright infringement or the loss of human-centric artistic expression. The city of Strasbourg has recently decided to ban the use of AI in cultural communication campaigns. The argument is that cities cannot support artists while, at the same time, allowing the use of a tool that can undermine the local creative ecosystem. The city will open a dialogue with artists, especially illustrators, to develop a common approach and set of guidelines.
• Financial resources and competences: not all cities have the data infrastructure and budgets to experiment with AI, with smaller municipalities particularly affected. Furthermore, city administrations often lack the internal expertise needed to evaluate, select and deploy the different solutions available.

Eurocities calls for an EU AI strategy for the cultural and creative sector that addresses the following priorities:

Reinforcing urban cultural ecosystems and local attractiveness

Municipal libraries, archives, museums and local heritage sites face resource constraints in digitising content and managing their data securely.

• There is a need for EU funds that can be used to guide cities on open-source AI tools and public data infrastructure so local cultural data isn’t exploited by AI platforms without local reinvestment or fair attribution.

Cities risk losing local talent and creative vibrancy if independent artists and local creative businesses are economically displaced by generative AI.

• Local administrations and cultural and creative workers need to be equipped for the AI transition.

Protecting cultural diversity and European cultural expression

European cultural policy consistently emphasises cultural diversity. There is growing concern that AI-generated content may amplify dominant languages, cultures and commercial content at the expense of local cultural expressions.

• AI systems should support, rather than homogenise, Europe’s diverse cultural ecosystems.
• Investment is needed in AI models that reflect Europe’s cultural diversity.

Strengthening the competitiveness and resilience of creative SMEs and freelancers

Most European creative businesses are micro-enterprises, freelancers or SMEs. Many lack the resources to access AI tools, expertise or computing infrastructure.

• Public intervention is needed to ensure AI adoption benefits the whole sector rather than concentrating advantage among large technology firms.

Safeguarding creators’ rights, remuneration and intellectual property

AI should strengthen, rather than weaken, Europe’s cultural and creative ecosystem. Across Europe, one of the strongest concerns of the cultural sector is that creative works, cultural datasets and heritage collections are being used to train AI systems without adequate consent, attribution or compensation.

• Cultural and creative sectors must not become net providers of value to AI platforms while receiving little economic return.
• EU and national frameworks should strengthen transparency regarding training data, attribution mechanisms, licensing models and remuneration systems for creators, rights holders and cultural institutions.
• Funding instruments should specifically support human creative production, innovation and new forms of human-AI collaboration.

Ensuring transparent and responsible use of AI, including at the local level

Public cultural institutions should lead by example in ensuring transparency in the use of generative AI. Local governments are often testbeds for innovative AI deployments in public spaces, public art and smart tourism.

• An EU-wide harmonised framework for labelling substantially AI-generated content in publicly funded or co-funded cultural communication across print media, digital services and social media could be developed.
• The role model function of publicly funded cultural institutions should be recognised.

Leveraging AI for data-driven urban cultural policies: building evidence and measuring impact

Cities generate massive amounts of data, from ticketing and foot traffic to public participation rates and demographic stats. These can revolutionise how urban cultural policies are designed, evaluated, and funded. However, local governments often lack the infrastructure, skills, or standardised systems to use this data effectively.

• Cities and cultural institutions require tools to assess economic, social and cultural outcomes from AI adoption.
• Better evidence is needed to guide future regulation, investment and workforce planning.

Embedding culture within the digital transition rather than treating it as a separate sector

European cities have long recognised culture as an enabler of innovation, place-making, democracy, inclusion and economic development.

• The cultural and creative sector should be viewed as active contributors to innovation, civic engagement, urban regeneration and inclusive growth.
• Culture should be integrated into wider digital, innovation and smart-city strategies.

Ensuring environmentally sustainable AI and digital cultural production

This issue is becoming increasingly prominent across Europe’s twin digital and green transitions. It is also one of the priorities of the Eurocities Lille Call to action on sustainable culture, already signed by 62 Mayors of large European cities.

• The cultural and creative sectors should be supported to adopt low-carbon digital infrastructure, sustainable computing practices and circular approaches to digital production.
• Environmental impacts should be considered as part of responsible AI deployment.

Fostering cultural participation and inclusion through AI

AI should allow a broader access to culture rather than create new barriers or reinforce existing inequalities. We therefore suggest that future EU actions:

• Promote AI applications that improve accessibility, multilingualism, cultural mediation and access to cultural knowledge.
• Ensure appropriate non-digital access to publicly funded cultural services and activities.
• Address potential biases in AI systems that may reduce the visibility of local cultural production or cultural practices that are less well represented in digital environments.
• Consider cultural diversity as quality criterion in the development and procurement of AI applications for the cultural sector.

Supporting cultural institutions as spaces for critical AI literacy

Public cultural institutions can be spaces where technological change is critically reflected upon and negotiated from social and cultural perspectives. This should be reflected in EU support to cultural organisations.

• Libraries, museums, theatres, cultural centres and other cultural institutions should be strengthened as spaces for public dialogue on the relationship between technology, creativity and society, and as spaces for media literacy to counter disinformation.
• Educational and outreach programmes should enable audiences, particularly young ones, to understand how generative AI works, its opportunities and limitations, and its social, cultural and ethical implications.

Empowering city culture with AI: How can the EU support cities?

• By helping cities to learn from each other through capacity building and upskilling. The EU should promote and support long-term peer learning schemes to identify new working models with AI that are tested in European cities, share their results, and assess their transferability to other local contexts.
• By channelling forthcoming EU funds (including Agora EU, Horizon Europe and cohesion policy funds) through municipal frameworks to support upskilling, AI literacy and fair transition funds to support local creation. Cities can act as living labs to experiment safely with ethical AI tools.
• By including indicators for the cultural and creative sector in the monitoring activities of the upcoming European AI Observatory.

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September 2026

Eurocities EU Transparency Register: 12493392840-79

Eurocities is the network of over 200 major European cities across 38 countries, representing more than 150 million people. Founded in 1986 and based in Brussels, it acts as a platform for local governments to exchange knowledge, influence EU policy, and develop sustainable, inclusive urban solutions.

Photo credits: Anna Stills