This paper has been commissioned by the Europeana Foundation to the Open Future Foundation as part of, and a contribution to, the ongoing Alignment Assembly on Culture for AI, a collective intelligence and consultation process that has been taking place within the common European data space for cultural heritage since May 2025. One of the key topics that emerged from the Alignment Assembly concerns the opportunities and challenges of positioning heritage data as responsible AI training material. This Impulse Paper explores that topic further, focusing on generative AI and its implications for data sharing in the cultural heritage sector. In doing so, it aims to provide further stimulus and input for discussion across the Europeana Initiative and the data space, and further scope one of the main topics identified in the Alignment Assembly exercise.
This Impulse Paper expands on the collective observations gathered through the Alignment Assembly. It is motivated by the belief that the common European data space for cultural heritage provides a unique opportunity to address the complex challenges and dilemmas raised by this topic. The Impulse paper is organised in two parts: the first outlines the relevant technological and legal context, and the second sets out a proposal for a differentiated access model for cultural heritage data.
The aim of this Impulse paper is to help develop a framework that supports cultural heritage institutions in deciding whether — and under what conditions — to make collection data available for AI training. Such a framework would greatly help institutions balance their commitment to open access and public information provision with the need to manage new forms of large-scale reuse that come with the rise of AI. In doing so, it seeks to chart a path for how cultural heritage institutions can contribute to a sustainable information ecosystem.
