EU R&I Ecosystem AI Futures: Final Report Key Recommendations

This is the fifth and final article in the series examining the futures of artificial intelligence and their implications for Europe's research and innovation ecosystem. Parts 1 through 4 addressed scenario framing, current sectoral adoption patterns, talent and skills dynamics, and governance architecture respectively. This final instalment presents the study's five integrated strategic recommendations, the implementation timeline to 2030, and what each recommendation means for businesses building AI products in the European Union.

The recommendations draw on the Joint Research Centre's foresight methodology, stakeholder consultations conducted across fourteen EU member states, and the regulatory framework established by the EU AI Act (Regulation 2024/1689). They are designed to be mutually reinforcing — each recommendation gains force when the others are also in place — and to create the conditions for European AI leadership in trustworthy, high-value applications rather than in raw model scale.

Recommendation 1: Strategic AI Infrastructure Investment

Europe's AI capability is constrained by compute infrastructure that lags both the United States and China in scale and concentration. The European High Performance Computing Joint Undertaking (EuroHPC JU) has made progress in establishing world-class supercomputing capacity, but AI training infrastructure for frontier models remains predominantly located outside European jurisdiction, creating both sovereignty risks and latency costs for European AI applications.

The study recommends targeted public investment in AI-optimised computing infrastructure, coordinated through the EuroHPC JU with private co-investment requirements modelled on the IPCEI (Important Project of Common European Interest) framework. Priority should be given to infrastructure accessible to SMEs and academic researchers on a shared-use basis, addressing the concentration of compute access among large cloud providers.

For businesses building AI products in the EU, expanded infrastructure investment translates into greater availability of EU-jurisdiction training and inference compute — reducing the compliance complexity of processing personal data on non-EU cloud infrastructure under GDPR Chapter V transfer restrictions.

Recommendation 2: Regulatory Sandboxes Under EU AI Act Article 57

Article 57 of the EU AI Act mandates that member states establish at least one AI regulatory sandbox by August 2026. Sandboxes provide controlled environments where innovative AI systems can be developed and tested with direct regulatory engagement and temporary derogations from certain compliance requirements, in order to accelerate learning about how emerging AI applications interact with the regulatory framework.

The study's recommendation goes beyond minimum compliance with Article 57: it calls for a networked European sandbox system that allows cross-border testing, harmonised admission criteria, and an EU-level observatory to aggregate learnings from national sandbox programmes into updated Commission guidance. The current fragmentation — where each member state develops its own sandbox criteria and processes independently — risks creating a patchwork that provides limited benefit to businesses operating across multiple EU markets.

Implementation timeline targets a pilot networked sandbox framework by Q4 2026, with full harmonisation by 2028. For businesses, the practical implication is that sandbox engagement should be considered a strategic tool, not merely a regulatory courtesy — participating businesses gain structured dialogue with competent authorities, early visibility on enforcement expectations, and potential derogations from Article 9 risk management documentation requirements during development phases.

Recommendation 3: Talent Mobility Across EU Member States

The EU AI talent landscape is characterised by significant concentration in a small number of research clusters — primarily around university-linked AI institutes in France, Germany, the Netherlands, and Sweden — while the broader European labour market faces severe shortages of AI practitioners with both technical depth and regulatory literacy.

The study recommends EU-level measures to increase AI talent mobility, including mutual recognition of AI-related professional credentials across member states, targeted fast-track work permit pathways for AI researchers from third countries comparable to Germany's Chancenkarte and France's Tech Visa, and co-funded mobility grants for AI researchers moving between member state institutions.

For businesses, talent mobility improvements address one of the most acute operational constraints in building EU-compliant AI products: finding engineers who understand both the technical architecture of AI systems and the compliance requirements under the EU AI Act. Article 9 risk management systems, Article 13 transparency documentation, and Article 17 quality management systems all require technical staff with regulatory awareness that today's labour market does not produce in sufficient numbers.

Recommendation 4: Data Sharing Under Data Act Article 5

The EU Data Act (Regulation 2023/2854) Article 5 establishes the right for users of connected products and related services to share their data with third parties. This is transformative for AI development: the primary constraint on European AI capability relative to US and Chinese incumbents is not algorithmic sophistication but training data access. European enterprises sit on vast operational data assets that are not currently accessible to AI developers at the ecosystem level.

The study recommends an active implementation programme for Article 5 data sharing rights, including standard technical interfaces for data portability, sector-specific data spaces (building on the GAIA-X initiative) in healthcare, mobility, and energy, and enforcement mechanisms to ensure incumbent data holders facilitate rather than obstruct lawful data sharing requests.

For AI product builders in the EU, Data Act Article 5 implementation represents the single highest-value regulatory development of the next three years. Access to rich, EU-jurisdiction training data — for which consent and lawful basis have already been established under GDPR — would fundamentally change the economics of European AI development, reducing dependence on synthetic data generation and enabling models trained on authentic European operational data.

Recommendation 5: International Partnerships Under EU AI Act Article 62

Article 62 of the EU AI Act provides for cooperation agreements with third countries and international organisations on AI governance, including reciprocal information sharing, joint research, and regulatory convergence. The study's fifth recommendation calls for an active EU international AI diplomacy programme to embed European AI governance standards in multilateral frameworks — building on the EU-US Trade and Technology Council AI governance dialogue and extending to engagement with the Global Partnership on AI (GPAI) and the OECD AI Policy Observatory.

Implementation by 2030 should include bilateral AI governance agreements with at least ten key trading partners, EU participation in international AI incident databases under Article 73 notification frameworks, and mutual recognition of conformity assessment bodies for AI systems traded internationally.

For businesses, international partnership frameworks reduce the compliance burden of deploying EU-developed AI in non-EU markets and, conversely, of adapting non-EU AI systems for EU deployment. The long-term goal is a global standard that aligns on the EU AI Act's risk-based architecture, making EU compliance a genuine passport to global markets rather than a barrier to entry.

Implementation Timeline to 2030

The five recommendations are sequenced around three phases. Phase 1 (2025-2026) focuses on infrastructure investment commitments and Article 57 sandbox establishment. Phase 2 (2026-2028) activates Data Act Article 5 data sharing mechanisms, launches the networked sandbox framework, and implements talent mobility measures. Phase 3 (2028-2030) consolidates international partnerships and evaluates the Article 62 agreements' effectiveness against benchmarks established in Phase 1.

Businesses building AI products in the EU should treat this timeline as a strategic planning framework: the regulatory and infrastructure conditions for trustworthy AI development will materially improve across the period, but the businesses that engage with regulatory processes early — through sandboxes, data sharing pilots, and talent investment — will be best positioned to capture the resulting opportunities.

Frequently Asked Questions

What is the EU AI Act Article 57 regulatory sandbox and how can businesses access it?

Article 57 of Regulation 2024/1689 requires EU member states to establish at least one AI regulatory sandbox by August 2026. Sandboxes provide controlled testing environments for innovative AI systems, with direct engagement from competent authorities. Businesses typically apply through national market surveillance authorities; admission criteria vary by member state but generally require that the applicant has an innovative AI system not yet deployed at scale and is prepared to share learnings with regulators.

How does Data Act Article 5 affect AI training data access in the EU?

Article 5 of the EU Data Act (Regulation 2023/2854) grants users of connected products the right to share their data with third parties, including AI developers, on request. For AI development, this creates a new lawful pathway to operational data that was previously inaccessible. Implementation depends on member state enforcement and sector-specific technical interface standards that are still being developed as of 2026.

What do the five strategic recommendations mean for businesses deciding whether to build AI products for the EU market?

Taken together, the five recommendations — infrastructure investment, regulatory sandboxes, talent mobility, data sharing, and international partnerships — describe an EU AI market that will become progressively more supportive of innovation while maintaining its governance standards. The EU AI Act's compliance requirements are real costs, but they are the entry price to a market of 450 million consumers with high AI adoption potential and a regulatory passport that is increasingly recognised globally.

Sources

• Regulation (EU) 2024/1689 (EU AI Act), Articles 9, 13, 17, 57, 62, 73
• Regulation (EU) 2023/2854 (EU Data Act), Article 5
• European Commission Joint Research Centre, Futures of AI in Europe — Final Report 2025
• European High Performance Computing Joint Undertaking (EuroHPC JU), Strategic Research and Innovation Agenda 2024
• European Commission, Communication on a European Strategy for Data, COM(2020) 66
• OECD AI Policy Observatory, AI Adoption in Industry 2024
• Global Partnership on AI (GPAI), AI Governance Frameworks Comparative Analysis 2024