AI Strategy for the Cultural and Creative Sectors

The European Commission is developing a strategy on artificial intelligence for the cultural and creative sectors and put out a call for evidence in July 2026. ITI submitted a response drawing on the translation profession's experience of the impact of AI.

Our full response, which addresses the value of human judgement in translation, the risk of skills loss as post-editing replaces translation, and the link between critical thinking and creativity, is available to read below.

The Institute of Translation and Interpreting (ITI) welcomes the Commission’s recognition that AI should complement rather than replace human creativity, and that cultural and linguistic diversity must sit at the centre of the proposed AI Strategy for the Cultural and Creative Sectors.

We offer the following observations from the translation and interpreting profession, which has a longer history of engagement with AI and machine translation than most other cultural and creative sectors, and can therefore speak to the practical impacts of sustained technological change.

Translation is more than a technical process

Producing a translation is not simply a matter of transferring information from one language to another. A professional translator understands meaning and intent, and produces the right sentence for the situation, the audience and the purpose, not the most statistically probable arrangement of words.

Languages carry the histories, memories and values of the people who speak them. A translator’s deep knowledge of both source and target cultures means that the translated message resonates with its intended audience, responding appropriately to nuance, tone, humour and cultural reference, and finding the right way to express an idea, such as an idiom, that has no literal equivalent. Professional translators are also ethical practitioners who are bound by a code of professional conduct and know when to flag a concern with a client, for example when language is not appropriately inclusive. Automated tools have no ethics and do not exercise judgment.

This is not a marginal consideration for a cultural strategy. The 2003 UNESCO Convention for the Safeguarding of the Intangible Cultural Heritage identifies language as a vehicle of intangible cultural heritage, noting that it is the means by which oral traditions, performing arts, social practices and traditional knowledge are expressed and transmitted between generations. Where such material crosses from one language into another, translation is not incidental to its survival; it is one of the mechanisms by which that heritage successfully reaches a new audience, or not. A strategy concerned with safeguarding European cultural and linguistic diversity should recognise that the professionals who mediate between languages are part of the infrastructure of heritage safeguarding, not simply providers of a commercial language service.

Linguistic diversity should be measured by more than volume

A strategy that succeeds only in increasing the quantity of machine-generated multilingual content in circulation will not necessarily have achieved greater linguistic diversity. Genuine diversity depends on the continued presence of skilled human professionals capable of exercising the judgement described above, particularly for languages and contexts poorly served by current AI training data. The strategy’s monitoring framework should reflect this distinction, rather than treating output volume as a proxy for diversity.

Vital skills, and the pipeline that sustains them

The translation profession illustrates a distinct type of skills risk that a strategy focused on innovation and productivity might otherwise miss: skills loss within an already-qualified workforce, not only a shortage of new entrants. As machine translation and generative AI tools become the default starting point for translation work, professional translators are increasingly asked to post-edit or correct machine output rather than translate a text themselves. Post-editing is a fundamentally different activity, drawing on a narrower set of skills. Sustained reliance on post-editing risks eroding the broader translating competence that professional translation depends on. A workforce that spends most of its time correcting rather than composing may, over time, lose some of the capability the strategy is seeking to protect.

The trend towards post-editing has also been associated with continuing downward pressure on rates in the translation sector, since post-editing is frequently priced lower than translation. This offers a plausible indication of what may follow in other cultural and creative fields as AI tools become similarly embedded, i.e. a shift in the nature of the work available, and in how that work is recompensed, that a headline measure of AI uptake would not capture.

These pressures compound concerns ITI has separately raised, in the UK context, about the decline of modern language provision and translation-specific postgraduate training in universities. If the profession becomes less attractive because of the move towards correcting machine output rather than translating the source text from scratch, while opportunities to acquire postgraduate qualifications in translation are also reduced, then the pool of people able to exercise critical judgement in translation risks shrinking from both directions at once.

We would urge the Commission to ensure that the strategy, and the education and training measures that flow from it, treat the maintenance of these vital skills and entry routes as an explicit objective, not something that can be assumed to follow automatically from “upskilling” or “reskilling” initiatives.

Critical thinking as a creative skill

The judgement referred to throughout our response is not a vague or intangible competence. It involves weighing context, resolving ambiguity, and anticipating how a text will be understood by a different audience. This is a form of critical thinking, which is the foundation of creativity more broadly. A strategy concerned with sustaining human creativity across the cultural and creative sectors should recognise that eroding the conditions by which this judgement is cultivated and practised represents a loss of creative capacity, not merely a loss of jobs.

What this means in practice

We would encourage the Commission to ensure that measures under this strategy, including those funded through Creative Europe, Digital Europe and Horizon Europe, are assessed against their potential impact on the pipeline and maintenance of skilled human professionals in language and other creative fields, not only against measures of AI uptake and productivity.