4.1.1 | European Edtech Map

EUROPEAN EDTECH POLICY MAP

4.1. Sustainable funding for spaces and structures for testing, trialling, co-creation

4.1.1 Include EdTech in subsidised AI environments, such as factories and sandboxes

Summary of suggested actions

Ensure that EdTech is explicitly included in subsidised European AI environments, such as AI Factories, regulatory sandboxes, and Eurostack infrastructure, to enable responsible experimentation, evidence generation, and digital sovereignty in the education sector.

Description

Europe’s subsidised AI ecosystems, including AI Factories, AI-on-Demand platforms, and regulatory sandboxes, provide structured environments for developing, testing, and validating artificial intelligence systems under ethical, legal, and technical safeguards. These initiatives, funded through the Digital Europe Programme and national AI strategies, primarily focus on industrial or public-sector applications in health, manufacturing, and mobility.
The education sector remains underrepresented in these efforts, despite its strong potential to benefit from secure and evidence-driven AI experimentation. Including EdTech within these subsidised AI environments would allow developers, researchers, and education institutions to collaboratively test technologies under transparent governance conditions and in alignment with European values, such as data protection, fairness, and human oversight.
Participation in AI factories and sandboxes would also help generate robust, comparable evidence on system performance, user experience, and educational impact, strengthening the evidence base for EdTech procurement and scaling. Integrating education within Eurostack-type infrastructures — Europe’s sovereign cloud and AI service ecosystem — would further ensure that EdTech data and algorithms are processed and stored under trusted European standards, supporting both ethical AI use and strategic autonomy.

Major enabling factors

The Digital Europe Programme (DEP), Horizon Europe, and AI-on-Demand Platform already fund large-scale AI experimentation and capacity-building infrastructures suitable for extension to the education domain.
The EU AI Act and Coordinated Plan on Artificial Intelligence (2021) encourage Member States to establish sandboxes and shared testing facilities for AI development under ethical and regulatory oversight.
Countries such as France, Germany, Greece, and Finland have developed national AI factories and innovation hubs that can serve as templates for education-specific pilots.
The European Data Strategy and Eurostack initiative prioritise European-controlled cloud and AI infrastructure, which directly supports ethical and sovereign data management in education.
The introduction of the AI Act creates a regulatory incentive for EdTech developers to test and certify products in safe environments before market deployment.

Major roadblocks

Education and EdTech are rarely listed as priority sectors in national AI or digital innovation programmes, leading to limited eligibility for participation in AI sandboxes.
Many education institutions and EdTech SMEs lack the technical and legal capacity to engage in advanced AI testing environments.
Strict data-protection requirements in education complicate the use of real learning data for AI experimentation, even in secure sandbox settings.
Current AI testing environments prioritise technical performance over pedagogical or ethical dimensions relevant to education.
AI factories are often managed by industrial consortia with little representation from educational researchers or practitioners.

Suggested actions:
Defining EdTech and consistently including definitions

WHO (Potential actors)

European Commission (DG Connect, DG EAC) through the Digital Europe Programme, in cooperation with national ministries of education and digitalisation, national data protection authorities, AI innovation agencies, and EdTech associations.
Where applicable: Testing and Experimentation Facilities (TEFs), AI Factories, and European Digital Innovation Hubs (EDIHs) hosting education-related pilots.

WHAT (Goal of suggested activities)Integrate EdTech as a priority domain within subsidised AI environments such as AI Factories, regulatory sandboxes, and Eurostack infrastructures to enable compliant experimentation, evidence generation, and responsible AI deployment in education.

HOW (Suggested activities)

Designate education and training as a thematic focus within national and European AI sandboxes established under the AI Act.
Ensure the inclusion of education-specific use cases within the network of Testing and Experimentation Facilities (TEFs) and AI Factories funded by the Digital Europe Programme.
Provide targeted funding and technical support for EdTech SMEs and research institutions to participate in sandbox environments, covering compliance, data protection, and evaluation costs.
Facilitate cross-sector collaboration between regulators, EdTech providers, researchers, and educators to co-develop testing protocols addressing pedagogical, ethical, and legal criteria.
Establish a European EdTech sandbox network under the European Digital Education Hub to share lessons learned, anonymised datasets, and validated evaluation methodologies across Member States.
Require participating sandboxes to publish summary evidence reports on AI performance, fairness, and educational value to support evidence-informed policymaking and procurement.

Existing steps in the right direction

German “AI Factory” and TEF for AI

German Telekom’s AI Factory and Germany’s participation in the TEFs particularly in the health sector under the Digital Europe Programme provide infrastructure and governance for pre-market validation of AI systems. These facilities enable companies to test algorithms using real or synthetic data in secure and standardised environments.
The TEF model ensures compliance and safety in AI deployment by combining technical evaluation with regulatory support. Extending this approach to the education sector would enable the testing of EdTech AI applications — such as adaptive learning systems or assessment tools — under controlled, transparent conditions

Specific support required to achieve the Goal:

Establish a TEF for Education within the existing network, co-funded by the European Commission and Member States, to provide controlled environments for EdTech AI system testing and evaluation. This facility should include pedagogical experts, ethics boards, and educator participation to ensure that AI tools are evaluated against educational as well as technical criteria.

Finnish AuroraAI Programme

AuroraAI is Finland’s national AI programme aimed at integrating AI services across public sectors through a secure interoperability framework. AuroraAI is speeding up the establishment of an ecosystem serving the needs of citizens, public administration and industry. This is going to be made possible by creating snapshots across administrative boundaries about people’s true needs and the state of their wellbeing at key moments, including educational situations to tailor services and support.