The own-initaitive report is a legislative procedure led by the Committee on Culture and Education (CULT) to address the impacts, challenges, and regulatory needs of artificial intelligence on Europe's creative economy. NEMO’s statement, which was submitted to the report, emphasises that the debate about AI and culture must extend beyond individual creative professions and industries. It must also address the vast collections of digitised and born-digital cultural heritage held by museums, archives and libraries. These collections, together with their metadata, provenance and professional documentation, constitute a strategic European asset that should be protected from uncontrolled extraction and used responsibly for the public benefit.
Museums are essential partners in shaping trustworthy AI
Museums hold an important position in the AI landscape. They are long-term stewards of cultural, historical and scientific knowledge, as well as highly trusted public institutions. Their collections can contribute to the development of culturally diverse and trustworthy AI systems, while their public role enables museums to strengthen critical AI literacy, provide authoritative context and create spaces for democratic dialogue. NEMO therefore calls for museums to be recognised not simply as users of AI tools, but as active partners in the development and governance of European AI policy.
Sustainable investment in infrastructure and people
For museums to make their collections available responsibly, Europe must invest in the infrastructure that enables trustworthy cultural data. This includes digitisation, high-quality metadata, provenance and rights information, interoperable collection-management systems, secure storage, persistent identifiers and sustainable data delivery.
As museums hold valuable cultural, scientific and research data, they must also be included in European and national cybersecurity and resilience frameworks, with targeted support for preparedness, training and incident response.
NEMO also stresses the importance of investing in people and leadership. Museum directors, senior managers and governing bodies need the knowledge and confidence to define how AI should support their institutions’ missions, collections, audiences and public responsibilities. This includes the ability to assess risks, establish accountability, protect professional expertise and decide when AI should not be used.
Open access must be protected and made sustainable
NEMO reaffirms museums’ commitment to open access and the reuse of cultural heritage in the public interest. However, the statement distinguishes between access for citizens consulting individual objects and the large-scale automated extraction of museum data for commercial use or AI training. While public-domain cultural heritage should remain as open as possible, high-volume access places additional demands on publicly funded infrastructure.
NEMO therefore proposes differentiated models of machine access. Programmatic or bulk access could be provided through documented interfaces and transparent, fair and non-exclusive arrangements. Commercial actors making intensive use of museum data and digital services should contribute proportionately to the infrastructure, professional work and ongoing maintenance that make this material available. Such arrangements must not create new exclusive rights over public-domain heritage or limit access for research, education and other public-interest purposes.
NEMO’s key recommendations
In the statement, NEMO calls on the European Parliament and European and national decision-makers to:
- Recognise museums as essential actors in European AI policy, including as trusted public institutions, stewards of cultural heritage data, public educators and spaces for democratic dialogue.
- Invest in museum infrastructure and data readiness, including digitisation, metadata, interoperability, provenance, secure systems, cybersecurity and long-term maintenance.
- Protect open public access while allowing differentiated machine access, particularly for resource-intensive commercial reuse and AI training.
- Require transparency, attribution and provenance, so that museums can understand how their data is obtained, transformed and used by AI systems.
- Ensure fair contributions from commercial users, allowing value generated from professionally curated cultural data to support the institutions and public infrastructure that sustain it.
- Invest in museum professionals, leadership and organisational capacity, enabling institutions to develop mission-led AI strategies and preserve human authority and expertise.
- Establish a coordinated European capacity-building hub that brings together available training, guidance, multidisciplinary expertise and peer learning, including dedicated support for museum leaders and governing bodies.
- Include museums in European and national cybersecurity and resilience frameworks, with dedicated assistance for preparedness, risk assessment and incident response.
- Protect cultural and linguistic diversity, including safeguards for sensitive, sacred, Indigenous and community-controlled knowledge.
- Monitor AI’s impact on museum work and environmental sustainability, including verification workloads, deskilling, dependency on proprietary systems and the environmental costs of AI applications.
Dive deeper into the topic with us at the NEMO European Museum Conference
Explore AI and its impact on the cultural sector with us at the NEMO European Museum Conference 2026: Human after all – Museums in the wake of AI, taking place 11–13 October 2026 in Vilnius, Lithuania.
The conference will bring together museum professionals from across Europe to explore how museums can navigate AI, digital transformation and cybersecurity while remaining people-centred, trustworthy and resilient institutions. Through presentations, discussions and hands-on workshops, participants will examine both the opportunities and challenges that AI presents for the museum sector.
