SAA - Society of Audiovisual Authors

EU Commission call for evidence on an AI Strategy for the CCSs

11 September 2026 Contributions
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The SAA response to the European Commission's call for evidence on an EU Artificial Intelligence Strategy for the Cultural and Creative Sectors is that of which AI complements, not replaces, authors' creativity, strengthens access to culture and knowledge, and supports original European works.

The SAA central position is that AI must not deepen the already precarious economic situation of audiovisual authors, whose works and livelihoods are threatened by unlicensed training and by competition from lower-cost AI-generated content. The strategy should therefore protect authors’ rights, prevent the substitution of human-made works, ensure transparency when AI is used in audiovisual creation, and encourage sector-specific codes of practice based on trust and consent. The SAA calls for stronger implementation of the DSM Directive’s principle of appropriate and proportionate remuneration, including statutory, collectively managed remuneration rights across all forms of exploitation, particularly streaming, video-sharing and social-media platforms, so screenwriters and directors share fairly in the economic success of their works. It considers collective management organisations essential partners for efficient, ethical licensing at scale.

The SAA’s core demand is to put ART - Authorisation, Remuneration and Transparency - at the centre of the strategy: AI companies must obtain authorisation to use protected works; pay fairly for both past and future use; and disclose the copyrighted material used to train their models, with a presumption of use where disclosure is missing. To make this effective, the SAA urges the EU to narrow text-and-data-mining exceptions, reinforce the AI Act’s transparency rules, and replace the ineffective opt-out model with a framework that places the responsibility on AI companies to seek permission. Finally, the strategy must safeguard cultural diversity and the visibility of European works, including through stronger promotion obligations and transparency around recommendation algorithms.

Download the contribution below to read the SAA's full response.