RESPONSE by the EUROPEAN WRITERS’ COUNCIL CALL FOR EVIDENCE FOR AN INITIATIVE (without an impact assessment):“AI Strategy for the Cultural and Creative Sectors” –Ref. Ares(2026)7389748 – 27/07/2026

To the attention of Directorate-General for Education, Youth, Sport and Culture – Unit D1 for Cultural Policy

Brussels, 11^th September 2026

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. EWC Members comprise over 260,000 professional authors in the book sector, writing in 37 languages and publishing in all genres (fiction, non-fiction, educational, academical, children & young adult, poetry).

In response to the Call for Evidence, we have enclosed a detailed contribution. We are aware that the Directorate-General responsible is not permitted to impose legislation.

Nevertheless, we expect the relevant EU Commissioner, the esteemed Glenn Micallef, to finally begin turning words into action.

Summary of EWC’s response

I. Preamble: AI FOMO leads to turning a blind eye on damages done and foreseen

• Writers are the originators of the value chain, yet they are the last to receive support.

II. Sovereign wording, confident stance: to know what AI is and what it is not is key to regulating it

• Gaps in the European policy should be filled with a technically informed approach.

III. The challenges for writers and translators arising from the use of AI in the book sector:

• Machine-generated products have no economic benefit for writers-only for fraudulent actors.

IV. The protection of authors’ rights, copyright and related rights, including transparency regarding the use of protected works for so-called “AI training” and the need for an appropriate and proportional remuneration:

• The EWC’s remedy calls for the removal of the TDM exception, and future regulation under the ART-principle (Authorisation, Remuneration, Transparency);
• The EWC calls for trust and transparency as enforceable key principles: neither the template of the AI Act nor the transparency obligations are sufficient to let Europe’s CCS survive.

V. The impact of AI on creative professions, working conditions, skills and employment:

• The EWC calls for a comprehensive EU-wide study on the economic harm done by AI products related to: Input; Output; and impact on income, pension schemes, tax, and cultural funding;
• The EWC calls for checks and balances for literacy, and to continue job creation action plans including access to adequate social protection for those affected by AI-related job losses;
• The EWC calls for safeguarding the freedom to say “no” to any AI-adaption of their works.

VI. The preservation of cultural and linguistic diversity of European works:

• EWC proposals for targeted funding, exchange and educational programmes;
• The EWC calls for a legislative work on active anti-discrimination in the discoverability of European cultural works, like the AVMS Directive (EU) 2018/1808.

VII. Needed policy and regulatory measures

• Conduct an EU wide study on the market harm and socio-economic impact of so-called generative AI;
• Seek remedies for the damage caused by copyright infringement;
• Remove the non-applicable TDM exception(s), to allow voluntary and individually negotiable licensing by authors and with appropriate and proportionate payments, without posing any further “AI exception” or mandatory licensing upon authors and further rightsholders;
• Encourage Member States to set up mediation entities for authors who wish to say “no” to the use of their works within TDM, GPAI, or generative AI usage;
• Initiate an adjustment of EU competition law, so that authors’ associations are allowed to publicly advise on contracts, clauses, remuneration, and how to deal with unauthorised AI adaptation;
• Set up a human-readable labelling system for AI-fabricated products of all kinds;
• A legislation on active anti-discrimination for the discoverability of European cultural works;
• A dedicated Directive for the social protection of authors, artists, and cultural professions.

 

To the full EWC contribution (pdf, 15 pages)

To EWC’s response on the EU Survey-Website

Related EWC responses to Consultations and EU-Surveys:

8 Demands for a sustainable future of Authors’ Right in the era of so-called AI: EWC response on the CALL FOR EVIDENCE

EWC contributed to the Call of Evidence for the Culture Compass