Mapping AI in Higher Education: Key Guidelines and Policy Recommendations
In a rapidly evolving AI landscape, clear policy guidelines for AI in Higher Education are essential, not only for educators and learners, but for all stakeholders within the European Education ecosystem. To date, although several key documents offer guidance on the use of AI in educational settings, none of them focus specifically on Higher Education, which is a sector that presents unique challenges and specificities, often overlooked by policies that have been primarily designed with primary or secondary education in mind. Nevertheless, it is important to identify where Higher Education fits within the current set of European policy and guidelines on AI that are often referenced as future-guiding instruments.
All the documents referenced in this mapping exercise below, are provided as publicly available documents at the end of this post.
The AI Act
While the EU Commission’s flagship policy on AI, the AI Act, is primarily a regulatory framework aimed at establishing a unified approach to AI across sectors, it includes two noteworthy references to education. First, a key passage (56) underlines the importance of deploying AI systems to promote high-quality digital education and training:
- “Passage 56: The deployment of AI systems in education is important to promote high-quality digital education and training and to allow all learners and teachers to acquire and share the necessary digital skills and competences, including media literacy, and critical thinking, to take an active part in the economy, society, and in democratic processes”
Second, Article 4 focuses on enhancing AI literacy by mandating that providers and deployers ensure that their staff and users are adequately trained. Although the Act does not explicitly target higher education, these recommendations offer valuable points that universities can incorporate into their digital transformation strategies.
- “Chapter I, Article 4: Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.”
In addition, the EU AI Act identifies several categories of AI systems in education as high-risk. These include systems used to determine access or admission to educational institutions, evaluate learning outcomes (including steering the learning process), assess the appropriate level of education for individuals, and monitor for prohibited behaviour during tests.
- “Annex III, passage 3: Education and vocational training: (a) AI systems intended to be used to determine access or admission or to assign natural persons to educational and vocational training institutions at all levels; (b) AI systems intended to be used to evaluate learning outcomes, including when those outcomes are used to steer the learning process of natural persons in educational and vocational training institutions at all levels; (c) AI systems intended to be used for the purpose of assessing the appropriate level of education that an individual will receive or will be able to access, in the context of or within educational and vocational training institutions at all levels; (d) AI systems intended to be used for monitoring and detecting prohibited behaviour of students during tests in the context of or within educational and vocational training institutions at all levels.”
Although this passage does not serve as a comprehensive guide for AI use in education, it highlights key activities that any future Higher Education-specific policy must address to ensure responsible and safe AI deployment.
AI for Europe
The European Commission’s 2018 Communication Artificial Intelligence for Europe provides an early strategic vision for how the EU should approach AI across sectors. While not a guideline, it sets the tone for many subsequent policy developments. This document acknowledges that the digital transformation driven by AI will reshape work, education, and society, and explicitly emphasises that the modernisation of education at all levels should be a priority for governments. The first mention of Education in this document is found in the Introduction:
- “No one is left behind in the digital transformation. AI is changing the nature of work: jobs will be created, others will disappear, most will be transformed. Modernisation of education, at all levels, should be a priority for governments. All Europeans should have every opportunity to acquire the skills they need. Talent should be nurtured, gender balance and diversity encouraged.”
This passage highlights that the modernisation of education is a priority for the EU. Although Higher Education is not singled out in detail in the AI for Europe, it mentions the need for inclusiveness and interdisciplinarity in AI education and training, which are highly relevant values in Higher Education.
- “Nurturing talent, diversity and interdisciplinarity. Europe should strive to increase the number of people trained in AI and encourage diversity. More women and people of diverse backgrounds, including people with disabilities, need to be involved in the development of AI, starting from inclusive AI education and training, in order to ensure that AI is non-discriminatory and inclusive. Interdisciplinarity should also be supported (by encouraging joint degrees, for example in law or psychology and AI). The importance of ethics in the development and use of new technologies should also be featured in programmes and courses.”
Finally, the document references the European Institute of Innovation and Technology (EIT) which integrates AI across the curricula it supports, setting an example of institutional AI integration that Higher Education institutes could follow.
- “The European Institute of Innovation and Technology (EIIT) will integrate AI across curricula in the education courses it supports, in order to contribute to developing a talent pool for AI in Europe.”
While broad in scope, this early communication document sets foundational principles that are especially pertinent for shaping Higher Education AI strategies going forward.
Digital Education Action Plan (DEAP)
The DEAP (2021–2027), produced in 2020, is an important brief document that sets the plan forward by the EU Commission, outlining a strategic framework to reset education and training systems for the digital age. Although not exclusively targeting Higher Education, the plan includes several AI-related actions relevant to the tertiary sector. These include incorporating AI and digital skills into the European Digital Competence Framework, developing AI learning resources for educators, and creating ethical guidelines on AI and data use in education. These initiatives support the upskilling of education providers and the responsible integration of AI tools.
- “Actions to Take: Include AI and digital skills in the European Digital Competence Framework. Support the development of AI learning resources for education & training providers. Develop ethical guidelines on artificial intelligence and data usage in teaching and learning and support related research & innovation activities through Horizon Europe.”
One of the most significant outputs from the DEAP is the publication of the 2022 Ethical Guidelines on the Use of Artificial Intelligence (AI) and Data in Teaching and Learning for Educators, which aims to raise awareness about the AI use in education and flag up the possible risks, including ethical ones. These guidelines emphasize transparency, data protection, and ethical practices, principles that are universally applicable for the use of AI. Nevertheless, these guidelines also provide practical examples for the use of AI in education (“Using AI to teach students, Using AI to support student learning, Using AI to support the teacher, Using AI to support diagnostic or system-wide planning”), as well as provide a guide for the planning for effective use of AI in a School, and the emerging competences needed for the ethical use of AI.
While the primary target of these Guidelines seems to be secondary education, the core ethical framework and practical orientation provide a valuable reference for Higher Education institutions too. This seems to be currently the closest document to a guideline for the use of AI in Higher Education.
The EU Commission’s European Digital Education Hub: The AI Report
The European Digital Education Hub (EDEH) is an initiative of the European Commission that brings together education stakeholders to share practices, co-create knowledge, and support the digital transformation of education across Europe. The EDEH’s AI Report is a practical and strategic policy-oriented document. It outlines competence frameworks for teachers, highlights implementation guidelines, and provides real-world use cases of AI in education, with a strong emphasis on teacher training, institutional support, risk categorisation, and ethical deployment.
One of the core contributions of the AI Report is its structured distinction between competences for teachers when “Teaching for AI”, “Teaching with AI”, and “Teaching about AI”, helping to clarify the different pedagogical roles educators may assume, from fostering general AI literacy among students (teaching for AI), to using AI tools in instructional practice (teaching with AI), and to instructing students directly in AI technologies and methods (teaching about AI).
Although the AI Report is not tailored to Higher Education, it is conceptually and strategically useful for it. University policymakers, teaching and learning units, and faculty developers can draw on its models and recommendations, especially in areas like institutional policy, ethical AI deployment, and educator competencies. However, adaptations are needed when applying its recommendations to Higher Education settings, in order to ensure alignment with the pedagogical models, professional autonomy, and structural differences of Higher Education.
The EU Commission’s European Digital Education Hub: Understanding AI in Education
This EDEH document serves as a foundational briefing focused on the importance of Explainable AI (XAI) in educational contexts. It aims to build foundational understanding among educators about how AI works and how it should be approached in education, and offers conceptual clarity around key terms such as transparency, interpretability, and ethical design, while also linking AI deployment with established pedagogical theories. Although not specifically designed for Higher Education, the insights of this document are relevant and could be adaptable to Higher Education.
European University Association: Artificial Intelligence Tools and Their Responsible Use in Higher Education
This is the only policy-oriented European document that has been developed specifically to analyse the AI use in Higher Education. Published in 2023, the EUA report provides a clear position on the responsible, ethical, and transparent use of AI tools in university learning and teaching. It identifies both risks (e.g., data bias, privacy, academic integrity) and opportunities (e.g., personalised learning, process efficiency), while strongly advocating for institutional adaptation rather than prohibition. A key message from the document is that banning AI tools is not a viable option; instead, universities must revise their assessment and teaching practices to incorporate AI in line with academic values and societal impact. Although not a comprehensive guideline, this document represents a crucial step toward sector-specific policy thinking for AI use in Higher Education.
UNESCO’s Quick Start Guide on ChatGPT and AI in Higher Education
Although not an EU document, the UNESCO guidelines for the use of AI in Higher Education (published in 2023) is one of the most important and one of the few international guides explicitly designed for Higher Education. It provides a practical introduction to ChatGPT, explains how it can be used in teaching, research, administration, and community engagement, and raises key ethical, regulatory, and pedagogical considerations for its adoption. A central contribution of the guide is its emphasis on institutional adaptation: Higher Education institutions are encouraged to build capacity, train staff and students, conduct AI audits, and integrate AI into curricula and assessment practices. The guide frames ChatGPT not merely as a tool but as a transformative driver that requires strategic alignment with academic integrity and human-centred values.
Institute for Ethical AI in Education: The Ethical Framework for AI in Education
Developed through international consultation, this framework provides ethical guidance for educational leaders, technology providers, and policymakers. Unlike other documents, it presents its recommendations in the form of a structured table, with clear objectives, evaluation criteria, and checklist items, making it particularly useful as a practical tool or rubric. Although its focus is mainly on school education, its emphasis on procurement, ethical design, and institutional responsibility is highly relevant to Higher Education contexts.
Conclusion
The mapping presented above, reveals that while multiple European and international documents address AI in education, but none fully capture the distinct realities, responsibilities, and strategic needs of Higher Education institutions. Existing frameworks often generalise across sectors or focus on school-level education, overlooking the unique pedagogical models, governance structures, research dimensions, and ethical challenges present in universities. As AI becomes more embedded in academic practice, a coherent, sector-specific European guideline is needed; one that supports institutions in adopting AI responsibly, aligning with academic values, safeguarding integrity, and fostering innovation. A dedicated EU policy on AI in Higher Education would not only be non-redundant, it would be a timely and necessary advancement to ensure that universities remain both critical adopters and ethical stewards of AI technologies; a guide that is urgently needed.
Source: University of Cyprus | Latest news (https://tinyurl.com/mr3ehbvz)