Music, Heritage, and Policy in the Age of AI

Music, Heritage, and Policy in the Age of AI Building the Diversity Pillar of the European Music Observatory with Federated Knowledge Graphs Antal, Dániel Jankovič, Marián Mester, Anna Márta Mikš, Tomaš Table of contents Abstract....................................... 3 Introduction........................................ 5 Findings of the Feasibility Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Policy Context and Relationship to the Green Paper . . . . . . . . . . . . . . . . . 11 European Cultural Policy Framework: Compass, Data Hub, and Music as a Forerunner ................................. 11 Analytical Foundations: From the CITF Background Study to the OpenMusEGreenPaper............................. 13 The Green Paper in a Nutshell: Section Overview . . . . . . . . . . . . . . . . 14 From Analysis to Implementation: CITF First Project (Books) and Music as aParallelCase ............................... 15 Diversity and Circulation as the Other Side of the Economic Equation . . . . 17 From Policy to Implementation: Governance, Architecture, and Semantic Design . 18 Governance as an Implementation Method . . . . . . . . . . . . . . . . . . . . 18 Architectural Commitments under Policy Constraints . . . . . . . . . . . . . 21 Semantic Design as Policy Translation . . . . . . . . . . . . . . . . . . . . . . 22 Methodological Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Data Modelling and Representation . . . . . . . . . . . . . . . . . . . . . . . . 26 Interoperability Mechanics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Technical Publication and Scalability . . . . . . . . . . . . . . . . . . . . . . . 30 Cross-Context Validation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Diversity Goals Without Exposure of Sensitive Data . . . . . . . . . . . . . . . . . 33 The Diversity & Circulation Aspects of European Music Policy . . . . . . . . 34 Application Layers and System Architecture . . . . . . . . . . . . . . . . . . . . . . 39 Public-private governance and data protection . . . . . . . . . . . . . . . . . . 40 PublicAccessLayer ................................ 42 Case Study: Computing Local Content Indicators from Official Charts . . . . . . . 45 Datasourcesandscope .............................. 45 Rationale for the use of official charts as a neutral reference corpus . . . . . . 45 1 Microdata layer: recordings and works . . . . . . . . . . . . . . . . . . . . . . 46 Internal evaluation and indicator logic . . . . . . . . . . . . . . . . . . . . . . 47 Aggregation and observatory-level representation . . . . . . . . . . . . . . . . 47 Interpretation limits and policy relevance . . . . . . . . . . . . . . . . . . . . 48 DiscussionandOutlook ................................. 48 References......................................... 50 AnnexA:DataUsed................................... 54 PersonalData.................................... 54 Locationandnationality.............................. 55 RepertoireData................................... 58 Soundrecordings.................................. 58 RecordingTitle................................... 59 Identifiers...................................... 60 Release ....................................... 63 2 Abstract Across Europe and other advanced music markets, cultural policy instruments such as local content quotas, diversity targets, and equality pledges are widely used to sustain domestic cultural ecosystems. As discussed in the OpenMusE Green Paper on AI, Data Governance, and Metadata Policies for Europe’s Music Ecosystem, these instruments have repeatedly struggled at the point of implementation, particularly under conditions of platform scale and data protection constraints. Broadcasters, festival organisers, and other cultural intermediaries are expected to meet quantitative targets, yet they often lack reliable, auditable, and legally safe tools to assess compliance in practice. This paper responds to that policy analysis by presenting the Slovak Comprehensive Music Database (SKCMDb) as an implementation-level pilot within the Open Music Observatory. SKCMDb operationalises diversityand locality-related policy criteria through a federated, governance-by-design data infrastructure. Rather than exposing personal attributes of composers or performers, the system separates internal evaluation from external disclosure, expressing policy-relevant outcomes as properties of cultural artefacts. This approach enables the computation of eligibility and diversity indicators while respecting the General Data Protection Regulation, non-discrimination principles, and institutional competences. The paper situates SKCMDb within a broader ecosystem of interoperable modules, including the Hungarian Music Database and community-curated Livonian and Karelian music databases, illustrating how the subsidiarity principle articulated in the Green Paper can be implemented across national, community, and supra-national levels. Methodologically, the work combines linked-data modelling, modular ontologies, and provenance-aware workflows with lightweight publication strategies. An empirical case study based on 156 weeks of official Slovak music charts demonstrates how local content indicators can be computed reproducibly and transparently using authoritative reference data, without monitoring individual broadcasters. The results illustrate the feasibility of diversity-aware cultural policy infrastructures envisioned in the Green Paper and support voluntary compliance, editorial decision-making, and comparative analysis. The paper concludes by outlining implications for European data governance, cultural policy, and the future development of the Open Music Observatory as a prototype European Music Observatory. ĹNote This is an early draft of the D2.1 deliverable of the Open Music Europe consortium. It has not been approved, amended, consulted with many contributors, and therefore it is not intended for use or citation. We make this version available in compliance with the Open Policy Analysis guidelines. The latest working copy is available here. Transparency note: Importantly, this document does not present a purely conceptual or speculative policy design. Substantial parts of the analysis synthesis lessons from policy-embedded implementation activities carried out using Open Policy Analysis methods1, including openly documented data, code, workflows, and methodological 3 decisions. These implementations were conducted in cooperation with public authorities and sectoral institutions, allowing the Green Paper to reflect not only policy aspirations but also the practical constraints and opportunities observed in real-world deployment. Following the principles of Open Policy Analysis, all related deliverables and technical documentation are publicly accessible to foster broad engagement and ensure a clear audit trail. Supporting documents for each chapter of this Green Paper are referenced in similar boxes. The current version (and future White Paper drafts) is available at https://zenodo.org/records/17075796. Standardised folders, figures, and bibliographies are available at https://github.com/dataobservatory-eu/open-music-data-whitepaper. Please note that this document puts the Open Music Observatory, a prototype of a modern European Music Observatory developed by the OpenMusE consortium, which is being currently populated with economy, diversity, society, innovation data and has already three federated modules, can reviewed in the technical documentation (see versioned Zenodo DOIs), our viewn on the temporary landing page. Funding acknowledgement: This project has received funding from the European Union’s Horizon Europe programme under Grant Agreement No. 101095295. The views expressed are those of the authors only and do not necessarily reflect those of the European Commission or its agencies2. Citation note: When citing this document, please use the latest versioned DOI available on Zenodo (current version: 10.5281/zenodo.17999571), and include the date of access if referring to material hosted on our GitHub repository.3This is an early 0.4.0 version.) 3The Guidelines for Open Policy Analysis form an actionable and practical set of directives that the OpenMusE consoritum was mandated to use under the Grant Agreement. It can be seen as good implementation framework for Evidence-based policy making in the European Commission and The practice of reproducible research [BITSS (2019); Open Music Europe (2023); (J 2015; Kitzes, Turek, and Deniz 2018). 3This document has been prepared by Open Music Europe (OpenMusE) project partners as an account of work carried out within the framework of this contract. Any dissemination of results must indicate that it reflects only the author’s view and that the Commission Agency is not responsible for any use that may be made of the information it contains. 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If you rely on supporting material hosted in the GitHub repository, please add the date of access in your reference. 4 Introduction Across Europe and other advanced music markets, cultural policy instruments such as local content quotas, diversity targets, and equality pledges have long played an important role in sustaining domestic cultural ecosystems. These instruments reflect a structural asymmetry between global cultural markets and national or regional creative production. While Englishlanguage popular music circulates globally with few barriers, music produced in smaller linguistic and cultural markets—such as Slovak music—is consumed predominantly within national borders or among relatively small diaspora communities. For this reason, more than eighty countries worldwide apply some form of preferential treatment to local music and audiovisual production, most commonly through minimum usage shares for public broadcasters and, in many cases, commercial, regional, or community radio stations as well. In recent European policy debates, these long-standing instruments have acquired renewed significance in the context of the EU Culture Compass and the emerging EU Culture Data Hub, which aim to support cultural policy with timely, comparable, and evidencebased indicators. Within this framework, diversity and circulation metrics are no longer peripheral reporting tools, but core inputs for monitoring cultural ecosystems, assessing policy impact, and informing strategic decision-making at European level. Yet many of the indicators envisioned in these initiatives—particularly those related to diversity, local representation, and cross-border circulation—have historically been difficult or impossible to measure in a consistent and legally robust manner. Despite their long history, diversityand local-content policies have repeatedly struggled at the point of implementation. Broadcasters, festival organisers, and other cultural intermediaries are formally expected to meet quantitative targets, yet they often lack reliable, auditable, and ethically acceptable tools to assess compliance in practice. In the absence of such tools, implementation has frequently relied on informal editorial heuristics, institutional memory, or conservative programming strategies that privilege already well-known repertoire. These practices, while understandable, tend to undermine the intended goals of cultural diversity, renewal, and inclusion, and limit the usefulness of resulting data for European-level aggregation. The challenge is compounded by scale. Even before the introduction of the General Data Protection Regulation (GDPR), the rapid expansion of global music distribution platforms had already rendered traditional editorial knowledge insufficient. In the 1990s, a highly experienced radio editor or festival curator in a smaller European country might plausibly have maintained working familiarity with a few tens of thousands of recordings circulating through physical distribution channels. Today, global digital platforms provide access to well over one hundred million recordings. No individual editor can meaningfully survey such a repertoire, yet policy objectives increasingly apply across this vastly expanded universe of available content. This scale effect fundamentally alters the nature of categorisation, assessment, and comparability. These developments expose a structural mismatch between European cultural policy ambitions and the data infrastructures available to support them. The problem is not primarily 5 one of unwillingness or resistance among cultural intermediaries, but of missing coordination mechanisms capable of translating policy criteria into operational, computable indicators that can be aggregated across institutions and borders. At the same time, any viable solution must respect a core principle of European governance: subsidiarity. Cultural production, heritage, and identity are inherently situated, and data infrastructures that feed into European-level instruments such as the Culture Compass must therefore operate across local, national, and supra-national levels without collapsing these distinctions into a single, centralised system. Figure 1: https://openmusicobservatory.eu/ The work presented in this paper emerges from this insight. It introduces the Open Music Observatory (OMO)—and in particular its Diversity and Circulation pillar—as a forerunner and model component of a future EU Culture Data Hub. Through the concrete implementation of the Slovak Comprehensive Music Database (SKCMDb), developed alongside comparable initiatives such as the Hungarian Music Database and community-curated Finno-Ugric music databases, the paper demonstrates how diversity and circulation indicators that were previously considered impractical can be computed reproducibly and responsibly. In doing so, it illustrates how national and community-level data infrastructures can function as live, policy-relevant data sources for European instruments such as the Culture Compass. This paper proceeds as follows. • Section summarises the findings of the feasibility phase that motivated the work. Section situates the project within the European data governance agenda and outlines, in a concise “policy brief in a nutshell”, the relationship between this implementation work, the Green Paper, and current EU initiatives. • Section provides the path from policy to implementation with explaining governance, 6 architecture and semantic design under the EU’s data, cultural and music, and diversity policy umbrella. • Sections Section and Section describe the methodological foundations and the separation of internal evaluation from external disclosure. • Section presents the federated implementation and system architecture. • Section demonstrates the approach through a case study based on official Slovak music charts. The paper concludes by discussing implications for European cultural policy, data governance, and the future development of the Open Music Observatory as a prototype European Music Observatory within the EU Culture Data Hub. 7 Findings of the Feasibility Phase The Feasibility Study On Promoting Slovak Music In Slovakia & Abroad4identified a persistent and structural gap between the normative ambitions of cultural policy and the operational realities of music dissemination. While local content quotas and diversity objectives are typically articulated in legal or institutional terms, they are rarely accompanied by a technical or methodological framework that would allow their consistent application in everyday editorial practice. This gap was not merely practical, but conceptual: policy definitions often relied on categories that could not be coherently mapped onto the objects actually circulated by media platforms. A central finding concerned the mismatch between persons and cultural artefacts. Radio stations, streaming platforms, and broadcasters do not distribute composers or performers as such; they distribute recorded fixations of performances, that is, sound recordings. These recordings are cultural artefacts that do not themselves possess personal characteristics. Yet many quota systems implicitly assume that attributes of persons—such as nationality, age, gender identity, ethnicity, or place of residence—can be directly ascribed to the recordings through which music is communicated to the public. This assumption breaks down both conceptually and legally. Modern European cultural policy does not follow nineteenth-century ethnomusicological traditions that attempted to define what makes music intrinsically “Slovak”, “Hungarian”, or otherwise national. Contemporary quota systems instead operate through agent-based 4The study was published in English as Feasibility Study On Promoting Slovak Music In Slovakia & Abroad and Projektová štúdia propagácie slovenskej hudby na Slovensku a v zahranicí in Slovak (Daniel Antal 2020a, 2020b). 8 criteria: a recording may qualify as local or national if it is a performance of a musical work composed by a person born in, residing in, or otherwise connected to a given country; in other cases, language of lyrics or place of performance may be decisive. In Slovakia, for example, vocal recordings performed in the Slovak language may qualify irrespective of the performer’s place of birth, recording location, or ethnicity. A recording of Slovak folk music performed in Hungary by members of the Slovak ethnolinguistic minority may therefore legitimately count toward both Hungarian and Slovak quota systems. At the same time, European quota systems are constrained by fundamental legal principles, including the prohibition of discrimination based on ethnicity, nationality, or other protected characteristics. Cultural policy may promote linguistic diversity, local cultural ecosystems, or underrepresented groups, but it cannot lawfully categorise or exclude works on the basis of ethnic identity. This legal constraint is not a weakness of European quota systems; rather, it reflects a normative commitment to pluralism and equal treatment. It also opens space for precisely the kinds of cross-border and minority cases illustrated by Slovak folk music performed in Hungary or Hungarian-language folk traditions maintained by Csángó communities in Romania. The feasibility work was strongly influenced by insights from intersectional data feminism, particularly the recognition that data-related inequalities do not arise along a single axis, but through the accumulation and interaction of multiple structural asymmetries. In the global music industry, the visibility advantage of an American male star cannot be meaningfully compared to the position of a Slovak female composer, nor to that of a Csángó woman singing in a distinct Hungarian dialect in Romania. These cases sit at the intersection of linguistic marginality, gender imbalance, ethnic minority status, and unequal access to global distribution infrastructures. Treating any one of these dimensions in isolation risks reproducing, rather than mitigating, existing inequalities. Importantly, this intersectional perspective also revealed that diversity-oriented policies must not be framed as opposing “majority” and “minority” interests in simplistic ways. Most European national music ecosystems—regardless of internal gender or ethnic hierarchies— are themselves structurally marginal within the global music economy. From this perspective, the protection of cultural diversity includes not only historically marginalised groups, but also majority male performers operating within small national markets whose repertoire competes with overwhelmingly dominant global catalogues. A European diversity framework must therefore protect all participants in fragile cultural ecosystems, while remaining attentive to internal power asymmetries. These observations further complicate the already problematic linkage between personal attributes and recordings. A single sound recording may involve multiple composers, lyricists, performers, arrangers, and producers, each situated differently across axes of gender, language, ethnicity, nationality, and residence. Group identities are fluid, and personal circumstances change over time. Attempting to stabilise these attributes at the level of the recording risks both conceptual incoherence and ethical overreach, particularly under data protection law. The feasibility study therefore concluded that sustainable implementation requires a decoupling of internal evaluation from external disclosure, informed by an intersectional 9 collective management organisations, publishers, record labels, distributors, and platforms, each using overlapping data elements within distinct organisational and legal contexts. For this reason, the Open Music Observatory implementation explicitly follows the European Interoperability Framework (EIF)10, placing greater emphasis on the organisational layer that mediates between legal requirements and semantic alignment. This choice is not a departure from the CITF model, but a domain-driven extension that becomes necessary as workflow complexity increases. Governance arrangements in the two cases are likewise comparable. The CITF First Project emerged through voluntary, pioneer cooperation among willing Member States and sectoral institutions, without the creation of new mandates or the reallocation of legal authority. The Open Music Observatory follows the same governance logic. In Slovakia, cooperation is formalised through a Memorandum of Understanding that establishes shared principles for data stewardship, transparency, and open policy analysis while fully preserving institutional competences11. Replication efforts in Hungary and other regions follow similar voluntary patterns, albeit at different levels of maturity. In both cases, governance-by-design and trust-based cooperation are preconditions for implementation. The two projects also exhibit complementary strengths. The CITF First Project achieves broader geographical reach at an earlier stage, demonstrating that the model can be extended across multiple jurisdictions. The Open Music Observatory implementation prioritises depth over breadth, developing a more layered and workflow-sensitive implementation within a smaller number of territories. This trade-off is deliberate and informative: taken together, the two approaches show that the shared analytical model can scale both horizontally, across countries, and vertically, across increasingly complex organisational environments. Finally, the focus on diversity and circulation in the music case should be understood as analytically inseparable from economic and rights-related concerns. In data-driven cultural ecosystems, discoverability, circulation, and remuneration depend on the same underlying infrastructures of identification, authority control, and provenance. Music that cannot be reliably identified and made visible within such infrastructures cannot circulate effectively and cannot generate sustainable income for rightsholders. Diversity-oriented indicators and economic indicators therefore represent complementary perspectives on the same infrastructural problem. On this basis, the following sections describe the methodological and architectural choices through which the music implementation was realised, showing how policy objectives can be translated into concrete, interoperable data infrastructures in practice. 10European Commission. European Interoperability Framework – Implementation Strategy, 2017 (Commission and Digital Services 2017). 11Memorandum o porozumení o využití výsledkov analýz otvorených politík v kontexte slovenského kultúrneho a kreatívneho priemyslu a sektorových verejných politík v spolupráci s konzorciom pre výskum a inovácie s názvom OpenMuse. [Memorandum of Understanding on utilizing the Open Policy Analysis results of the OpenMuse Research and Innovation Consortium in the context of Slovak cultural and creative industries and sectors’ public policies] (Ministerstvo kultúry SR and Open Music Europe 2023) 16 Diversity and Circulation as the Other Side of the Economic Equation In the music sector, diversity, discoverability, circulation, and remuneration are not separate policy domains but interdependent outcomes of the same underlying data infrastructure. Music that cannot be reliably identified, contextualised, and linked across systems cannot be found by audiences, programmed by intermediaries, or remunerated through rights management systems. From this perspective, diversity indicators and economic indicators represent different views on the same infrastructural capacity: the ability of the ecosystem to make European music visible and actionable in data-driven environments. Historically, diversity policies have often been treated as normative or corrective instruments, while economic sustainability has been addressed through market mechanisms and rights enforcement. In digital music ecosystems, this separation no longer holds. Algorithmic discovery, platform analytics, and automated rights processing rely on shared metadata pipelines. Where these pipelines are fragmented or unreliable, both diversity objectives and economic outcomes fail simultaneously. A repertoire that is invisible to discovery systems will not circulate, and a repertoire that does not circulate will not generate income, regardless of its cultural value. The focus on diversity and circulation in this paper should therefore be understood as an analytical entry point into a broader economic problem, not as a departure from it. By examining how local, linguistic, and culturally specific repertoire can be made observable without exposing personal data or essentialising identity, the implementation described here addresses the same infrastructural conditions required for fair remuneration and sustainable markets. Diversity metrics become a stress test for the data infrastructure’s ability to support lawful, auditable, and scalable reuse. In this sense, diversity-oriented observability functions as an early and demanding use case. If an infrastructure can support reliable measurement of circulation and representation under strict legal and ethical constraints, it can also support more conventional economic indicators. The diversity and circulation pillar of the Open Music Observatory thus serves both as a policy-relevant implementation in its own right and as a proxy for the broader economic health of the European music ecosystem. 17 From Policy to Implementation: Governance, Architecture, and Semantic Design This section explains how abstract policy objectives are translated into concrete technical and organisational choices. It shows how governance arrangements, system architecture, and semantic design are treated not as downstream technical matters, but as primary implementation mechanisms shaped by legal constraints, institutional competences, and the principle of subsidiarity. The subsections that follow describe how governance-by-design, layered architectures, and modular semantic patterns jointly enable policy-relevant observability without centralising authority or exposing sensitive data. Governance as an Implementation Method From the outset, the Open Music Observatory implementations treated governance as a methodological problem rather than an administrative layer. European cultural policy is structurally multi-level: cultural competences reside primarily at national and regional levels (including federal and Länder-based systems), while the European Union operates through coordination, support, and aggregation. Any viable implementation must therefore align with this reality, enabling subnational, national, and supranational participation without assuming a single centre of authority. Governance, in this context, becomes the method through which policy objectives are translated into workable infrastructures across levels.12 At national level, this logic was formalised in Slovakia through a Memorandum of Understanding between the Ministry of Culture, its analytical unit (IKP), and the OpenMusE consortium, later amended with a more specific MoU among the SOZA,Slovak Music Centre, the Music Fund, and the Slovak National Library, and Reprex as the technology partner. Both MoUs deliberately avoids mandating data transfer, standardisation, or compliance. Instead, it establishes shared analytical principles—open policy analysis, methodological transparency, and non-exclusive cooperation—while preserving institutional competences.13 This governance choice is reflected in the technical design of the Slovak module, which is documented separately in the Open Music Observatory technical documentation and treated as a living specification rather than a fixed standard.14 • The Slovak Comprehensive Music Database is available at https://hudobnadatabaza.sk/. In Hungary, a comparable level of centralised coordination could not be achieved at the outset. As a result, the Hungarian implementation followed a deliberately bottom-up trajectory. Building on the Slovak template and its early public articulation in conference presentations, 12See the European Data Strategy and the emphasis on coordination, subsidiarity, and sectoral data spaces (European Commission 2020; European Parliament and Council 2022). 13Memorandum o porozumení o využití výsledkov analýz otvorených politík v kontexte slovenského kultúrneho a kreatívneho priemyslu a sektorových verejných politík v spolupráci s konzorciom OpenMuse (Ministerstvo kultúry SR and Open Music Europe 2023). 14Open Music Observatory: Technical Documentation (versioned, living documentation) (Daniel Antal 2024a). 18 the Hungarian work progressed through a series of bilateral agreements, exploratory workshops, and open professional discussions with individual institutions. This process involved sustained dialogue with archival, heritage, and research actors, rather than a single coordinating authority. While slower and more fragmented, this bottom-up approach proved well suited to the Hungarian institutional landscape and ultimately produced a governance structure aligned with local capacities, traditions, and trust relationships. In this sense, the divergence between the Slovak and Hungarian governance paths is not a deviation from the shared architectural vision, but an expression of the subsidiarity principle in practice15. The Hungarian implementation follows the same architectural and governance principles but emerged through a more bottom-up trajectory, reflecting different institutional histories and capacities. Cooperation developed incrementally through professional dialogue among archival, heritage, and research institutions rather than through a single coordinating authority.16 The Hungarian data sharing space does not have yet an end-user facing surface and an API. It exists as a data sharing space that connects several national-level databases, as explained in Enriching and Futureproofing the Databases of the Hungarian Heritage House17, and in the service integration around the databases of the Hungarian House of Music (explained later.) An emerging Polish track further illustrates how this governance pattern can be extended without requiring uniform legal instruments or synchronised institutional readiness. The Polish implementation is at an even earlier stage, and we are in the phase of replication design, and design of data curation workflows. Below the national level, the Finno-Ugric Data Sharing Space (FUDSS) makes subsidiarity operational in its most demanding form. It engages subnational and community-scale actors—regional archives, village museums, research groups, and community organisations— often operating across borders and outside state-scale cultural infrastructures. Such actors are frequently referenced in European policy discourse on cultural diversity, minorities, and regions, yet are rarely integrated into European data infrastructures in practice. The FinnoUgric Data Sharing Space includes community-curated databases for Livonian and Karelian musical heritage. In these cases, the institutional depth of a nation state—such as that available in Slovakia or Hungary—is largely absent. Livonian and Karelian heritage is preserved by a small number of dedicated regional GLAM institutions, research centres, NGOs, and community organisations, including the Livonian Institute. Under these conditions, a centrally coordinated governance model would be neither feasible nor appropriate. Instead, the implementation necessarily resembles community-driven approaches familiar from infrastructures such as Wikidata, MusicBrainz, or Discogs, albeit 15Presented at the annual conference of library and GLAM information management conference, the A szlovák adatkicserélési tér magyarországi föderációjának lehetőségei (Daniel Antal 2024d) was followed by numerous bilateral and open professional forums. 16See professional discussions and early replication pathways presented at HungarNet and related forums (Daniel Antal 2024d). 17A short feasibility study and early manuscript for publication, which is the developing manuscript for a separate publication (Daniel Antal and Zagyva 2025). 19 combined with more explicit data curation and governance safeguards. Authority is distributed, participation is voluntary, and trust is built through transparent methods rather than formal mandate. FUDSS functions as a methodological stress test for whether European frameworks can reach the smallest custodians of cultural heritage without forcing them into state-centric, platform-centric, or extractive governance models.18 • The Finno-Ugric Data Sharing Space is available at https://finnougric.net/. At the same time, the Open Music Observatory explicitly incorporates a supranational layer. Beyond the Slovak, Hungarian, Polish, and Finno-Ugric modules, a central observatory layer is designed to aggregate indicators, support comparison, and feed policy-relevant evidence upward without absorbing authority or data stewardship. This layer mirrors the governance position of European cultural infrastructures such as Europeana, the European Collaborative Cloud for Cultural Heritage (ECCCH), the Culture Compass, and the planned EU Culture Data Hub: coordinative rather than directive, integrative rather than extractive.19 Comparable governance logics have long been present in European broadcasting and cultural data coordination practices, including those developed within the EBU context.20 Taken together, these four modules—subnational (Finno-Ugric), national (Slovak), replicated national (Hungarian and emerging Polish), and supranational—constitute a governance model rather than a single system. They demonstrate how European cultural data infrastructures can operate simultaneously downward and upward: enabling the participation of the smallest cultural actors, supporting national policy implementation, and supplying aggregated observability at European level. In this sense, the Open Music Observatory does not merely align with Europeana,ECCCH, the Culture Compass, or the future EU Data Hub; it offers a concrete governance pattern for how such infrastructures can respect subsidiarity while remaining analytically and operationally coherent across Europe. This governance approach also provides the basis for a direct comparison with the Copyright Infrastructure Task Force (CITF) First Project. As discussed in the following subsection, both initiatives translate prior analytical work into concrete, voluntary implementations under real institutional constraints. The comparison is therefore not conceptual but practical: it examines how shared analytical principles—layered infrastructures, respect for competence, and governance-by-design—are realised in different cultural domains, with books and music presenting distinct but comparable challenges. The CITF First Project offers a reference implementation in a domain with relatively linear workflows and limited actor diversity (see Section ). The Open Music Observatory implementation operates at the same maturity level but addresses a structurally more complex ecosystem involving simultaneous coordination among libraries, collective management organisations, broadcasters, platforms, and community custodians. The governance patterns 18Federating Open Knowledge through Wikibase: The Case of the Finno-Ugric Data Sharing Space (Daniel Antal et al. 2025; Dániel Antal et al. 2025). 19Draft Joint Declaration “Europe for Culture — Culture for Europe” and related Culture Compass materials (European Parliament, Council of the European Union, and European Commission 2025). 20Governance practices discussed in European broadcasting and metadata coordination contexts, including CISAC and EBU-related forums (Mikš 2025). 20 outlined above—particularly the emphasis on subsidiarity, voluntary participation, and nonextractive aggregation—form the common ground on which this comparison is made. Architectural Commitments under Policy Constraints The architectural design of the Open Music Observatory is shaped by policy constraints rather than technical convenience. European cultural policy operates under strict limits on centralisation, competence transfer, and personal data processing. As a result, the architecture does not aim to consolidate music data into a single repository or to replace authoritative sectoral systems. Instead, it is explicitly designed as an observability layer: a structure that computes indicators, exposes aggregates, and links back to authoritative sources while leaving data ownership, stewardship, and legal responsibility in place21. Federation is therefore a foundational commitment rather than a transitional solution. The architecture assumes the coexistence of multiple authorities, heterogeneous data sources, and uneven institutional maturity across Europe22. National, subnational, community, and European-level components are treated as structurally distinct yet interoperable elements. This mirrors the logic of European cultural infrastructures such as Europeana and ECCCH and aligns with the design assumptions of the Culture Compass and the planned EU Culture Data Hub, which require comparability and aggregation without harmonisation by force. A second core commitment is the strict separation of authority, computation, and publication. Authoritative data remains under the control of competent institutions—libraries, archives, collective management organisations, broadcasters, and community custodians. The Open Music Observatory performs reconciliation, aggregation, and indicator computation without assuming decision-making authority over the underlying data. This separation is essential for lawful participation under GDPR, for maintaining institutional trust, and for enabling voluntary cooperation across public, private, and community actors23. The architecture also commits to workflow-aware interoperability. Music data circulates through fundamentally different organisational contexts, each with its own legal obligations, vocabularies, and practices. Rather than imposing a single semantic model, the 21This architectural position reflects core principles of the European Data Strategy and the Data Governance Act, which emphasise interoperability, data sovereignty, and the avoidance of unnecessary centralisation in public-interest data infrastructures (European Parliament and Council 2022). 22The federated observability model aligns with the governance logic articulated for Europeana, the European Collaborative Cloud for Cultural Heritage (ECCCH), and the Culture Compass for Europe, all of which rely on aggregation and coordination rather than directive control (BDVA/DAIRO Federation Working Group 2023; European Parliament, Council of the European Union, and European Commission 2025). 23This design choice reflects both European data protection law, in particular theGeneral Data Protection Regulation (GDPR), and the CARE Principles for Indigenous Data Governance, which complement FAIR data principles by foregrounding authority, responsibility, and ethical use in community and heritage data contexts (European Parliament and Council 2016; Carroll et al. 2020). 21 architecture accommodates overlapping and partially incompatible representations, focusing on alignment where necessary and divergence where meaningful. This approach reflects the European Interoperability Framework’s emphasis on organisational and semantic layers and recognises that semantic coherence in complex cultural ecosystems must be negotiated rather than enforced24. Finally, provenance and auditability are treated as first-order architectural constraints. Every indicator produced by the observatory is traceable to its source, transformation steps, and assumptions. This is not merely a technical safeguard but a policy requirement: without provenance, indicators cannot support accountability, nor can they safely feed into AI-driven environments or European-level policy instruments. By embedding provenance at architectural level, the Open Music Observatory enables continuous, auditable feedback into European cultural policy while respecting the limits of authority and competence that define the European governance model. Recent discussions within the European cultural heritage sector further underline the importance of provenance-aware data governance in the age of AI. A joint Impulse Paper by the Open Future Foundation and the Europeana Foundation examines how cultural heritage institutions can navigate large-scale data publishing and AI reuse while preserving public accountability, authority, and trust. It highlights that, once cultural data enters automated and AI-driven environments, incomplete or degraded provenance is no longer a marginal archival issue but a structural risk that shapes downstream use at scale. While the focus of that work is cross-domain, its conclusions closely resonate with the challenges observed in music, reinforcing the need to treat authority control, attribution, and lifecycle-aware governance as core infrastructural concerns rather than sector-specific exceptions. (Keller 2025) Semantic Design as Policy Translation In the Open Music Observatory, semantic design functions as a mechanism for translating policy objectives into computable form. Cultural policy concepts such as “local repertoire,” “diversity,” “circulation,” or “European works” are not natively machine-readable; they must be operationalised through explicit distinctions between works, recordings, performances, agents, and contexts of use. The semantic layer therefore acts as the point where legal definitions, policy intentions, and sectoral practices are reconciled into shared, auditable meanings. The design choices adopted here were not developed in isolation, but informed through sustained consultation with sectoral knowledge institutions and rights organisations. 24The emphasis on organisational and semantic interoperability follows the European Interoperability Framework (EIF), which explicitly recognises that legal, organisational, semantic, and technical layers must be aligned differently in complex, multi-actor public-sector ecosystems (Commission and Digital Services 2017; European Commission 2017). 22 Figure 3: fadas Our approach presented here was co-presented jointly with the Slovak Music Centre, an IAMIC member organisation, at the International Association of Music Information Centres General Assembly and Annual Conference (Music Austria, Vienna, 21 November 2024). Discussions with music information and documentation centres from several EU Member States focused on the feasibility of replicating the Slovak model—both its governance arrangements and its technical architecture—within different national institutional environments. See the presentation and poster format (Daniel Antal 2024c). We presented and discussed these ideas jointly with the Slovak Music Centre at the International Association of Music Libraries, Archives and Documentation Centers (IAML) during their General Assembly and Annual Conference (Salzburg, 7–9 July 2025), within the “Future Libraries” session and the poster session. See the presentation and poster format (Daniel Antal 2025a, 2025b). The discussion focused on the role of national music libraries and documentation centres as data stewards within federated cultural data spaces. Feedback from IAML participants contributed to clarifying the library-oriented replication pathway and helped accelerate the otherwise slow Hungarian replication process, supported by the positive reception of IAMIC Hungary. The exchange also identified potential future replication interest in Portugal, Finland, and Denmark, although these initiatives are likely to materialise beyond the timeline of the Open Music Europe project. These discussion reinforced the parallels with the first CITF project, highlighting the regulatory and standardisation roles of national libraries are authority control bodies (see Section ). 23 Figure 4: CISAC European Committee Meeting as OpenMusE: Towards a Sustainable Licensing Market for AI Use of Protected Works in Vilnius, on 29 April 2025. Our work was also presented at the CISAC European Committee Meeting as OpenMusE: Towards a Sustainable Licensing Market for AI Use of Protected Works in Vilnius, on 29 April 2025 (Mikš 2025) in comparison with similar metadata governance and repair initiatives from several countries. Our presentation differentiated itself from similar projects in Finland and the United Kingdom with not only fixing the metadata at source in the future, but also focusing on legacy metadata repair. Given that the current copyright and neighboring right protection terms will require rights managements for 20th century assets well into the later part of the 21st century, our focus on not only future-proofing, but past-proofing with legacy system interoperability set our approach apart. These consultations highlighted a recurring tension: the same musical artefact is described, classified, and used differently by libraries, archives, collective management organisations, broadcasters, and platforms. Semantic interoperability therefore cannot mean semantic uniformity. To address this, the Observatory adopts a modular semantic strategy based on ontological patterns rather than a single comprehensive schema. Core distinctions—such as between musical works, sound recordings, and performances—are stabilised, while domain-specific vocabularies are allowed to coexist at the edges. This enables alignment with library-oriented standards (e.g. authority control and bibliographic description), industry metadata practices (e.g. ISRC, ISWC, DDEX-aligned workflows), and rights-management perspectives, without forcing any actor to abandon its internal epistemology. This approach directly reflects feedback from IAML and IAMIC consultations, where national music libraries and documentation centres emphasised the need to preserve scholarly and archival integrity, as well as from CISAC-related discussions, where collective management organisations stressed legal precision, provenance, and accountability. Semantic design thus becomes a negotiated space: not an abstract exercise, but a governance-sensitive process that encodes institutional competences and legal responsibilities into the data model itself. In this sense, semantic design performs the same function for music diversity and circulation as the layered infrastructure does for copyright data in the CITF First Project (see Section ). In both cases, policy translation depends on making concepts computable without collapsing 24 institutional differences. The music case demonstrates that, as policy questions become more complex—combining cultural diversity, rights management, and algorithmic mediation— semantic design must explicitly account for organisational workflows and use contexts. This makes it a central implementation method, not a downstream technical detail. 25 or excessive harmonisation. This upward validation mirrors the role envisaged for European cultural infrastructures such as Europeana, the Culture Compass, and the future EU Culture Data Hub, where observability must coexist with subsidiarity. Beyond deployment contexts, cross-context validation was reinforced through structured engagement with professional and expert communities. Consultations and presentations at forums such as IAML, IAMIC, CISAC, Wikimedia community meetings, and European data governance events provided iterative feedback on modelling assumptions, governance choices, and interoperability strategies. These exchanges served as peer validation mechanisms, ensuring that methods remained intelligible and credible to practitioners operating under different constraints. Governance, federation, and data sovereignty issues were discussed in a broader crosssectoral context at Dataweek²� in Leuven, within the framework of the Big Data Value Association and Gaia-X31. Presenting the Open Music Observatory and its national modules as an example of a European music dataspace allowed the methodological approach to be evaluated against emerging governance expectations for federated data infrastructures, including principles of subsidiarity, non-extractive reuse, and institutional autonomy. Feedback from this forum directly informed the articulation of the federated data-sharing model described in the present paper. Our work was presented in the Technology sessions of the Wikimedia CEE Meeting 2024 (Istanbul) and the Wikimedia CEE Meeting 2025 (Thessaloniki), as well as at Wikidata Conf 2025 (online) (Daniel Antal 2024b, 2025c; Daniel Antal, Pigozne, and Federico 2025). These forums provided a practical testbed for validating modelling choices, editorial workflows, and governance assumptions against large-scale, community-maintained knowledge infrastructures. Taken together, these validation contexts demonstrate that the methodological framework of the Open Music Observatory is neither tailored to a single institutional configuration nor abstracted away from practice. Its robustness derives from being tested across national, subnational, community, and supranational settings, and from remaining adaptable without losing analytical coherence. This capacity for cross-context operation is essential if music observability is to function as a credible forerunner for wider European cultural data infrastructures. Through this engagement, we established working relationships with several national Wikimedia chapters and with the Wikidata and Abstract Wikipedia teams, and participated in the Wikidata Ontology Cleanup Task Force and the Wikidata Mereology Task Force. This involvement helped align our ontological patterns, identifier practices, and documentation strategies with broader open knowledge standards, while also ensuring that our approach to provenance, uncertainty, and institutional responsibility remains compatible with community-driven curation environments. 31Jun 5, 2024, Dataweek²�, Leuven, Belgium. 32 Diversity Goals Without Exposure of Sensitive Data The implementation of the Slovak Comprehensive Music Database (available at https://hudobnadatabaza.sk/), HUNDB (available at ), the Finno-Ugric Data Sharing Space (available at https://finnougric.net/) coincided with a broader shift in European policy thinking on data governance, artificial intelligence, and cultural infrastructures. Over the past decade, it has become increasingly clear that Europe’s capacity to pursue cultural, social, and economic objectives in the digital domain depends less on isolated regulatory instruments and more on the availability of trustworthy, interoperable data infrastructures. This shift is reflected in the European Data Strategy, the Data Governance Act32, and the growing emphasis on sectoral data spaces as instruments of public policy. In the cultural and creative sectors, this transformation has been driven in part by the rapid platformisation of music distribution and discovery. Recommendation systems, analytics pipelines, and increasingly generative AI models now mediate access to cultural content at a global scale. These systems rely on metadata that is often incomplete, inconsistent, or governed by commercial incentives that do not align with public-interest objectives. As a result, cultural policy goals—such as diversity, linguistic plurality, gender balance, or local content promotion—are difficult to articulate, let alone enforce, within algorithmic environments dominated by non-European actors. 32Regulation (EU) 2022/868 of the European Parliament and of the Council of 30 May 2022 on European data governance and amending Regulation (EU) 2018/1724 (Data Governance Act) (European Parliament and Council 2022) 33 Figure 6: “Recognising the EU’s supporting role in the field of culture, this declaration affirms shared political commitments and responsibilities of the European Parliament, the Council of the European Union and the European Commission - within their respective competencies and in full compliance with EU law - based on the key directions set out in the Commission’s 2025 Culture Compass for Europe.” 2. Cultural and linguistic diversity are fundamental values on which the EU is founded. We commit to: • Supporting, celebrating and preserving the rich cultural and linguistic diversity of the European Union and its cultural sovereignty. • Promoting the full diversity of cultural content created in Europe, notably online and harnessing new technologies to ensure the visibility and discoverability of this content. Draft Joint Declaration “Europe for Culture — Culture for Europe” (European Parliament, Council of the European Union, and European Commission 2025) The Diversity & Circulation Aspects of European Music Policy Against this backdrop, diversity quotas and local content regulations can no longer be understood as standalone cultural policy tools. Instead, they function as stress tests for Europe’s data governance ambitions. If a policy goal cannot be expressed in machine-readable terms, evaluated using auditable data sources, and implemented without violating fundamental rights, it risks becoming symbolic rather than effective. The monitoring and enforcement 34 gaps identified in earlier quota systems thus foreshadowed a more general problem: the absence of shared reference infrastructures capable of mediating between policy intent, data protection law, and algorithmic practice. European institutions have increasingly recognised this challenge. Rather than advocating for centralised databases or uniform metadata schemas, recent policy documents emphasise federation, interoperability, and governance-by-design. Data spaces are envisaged as socio-technical arrangements in which multiple actors retain control over their data, while agreeing on shared semantics, interfaces, and rules of engagement. This approach is particularly well suited to the cultural sector, where data is distributed across public institutions, collective management organisations, private platforms, archives, libraries, and community initiatives, each operating under different legal and ethical constraints. Within this framework, the principle of subsidiarity acquires renewed significance. Cultural identity, heritage, and creative production are deeply contextual and cannot be meaningfully governed through purely centralised mechanisms. At the same time, national solutions alone are insufficient in a digital environment characterised by cross-border circulation, global platforms, and transnational audiences. European data governance therefore requires multi-level infrastructures that operate simultaneously at community, national, and supra-national scales, without collapsing these levels into a single point of control. A defining feature of the Slovak Comprehensive Music Database is the strict separation between internal evaluation and external disclosure. While the system may internally process attributes that are relevant for diversity or local content criteria, it exposes only binary or aggregated outcomes. At the level of the recording, a track is reported as meeting or not meeting a quota requirement, without revealing which contributor, which personal attribute, or which specific criterion triggered eligibility. This separation is central to the viability of diversity-aware cultural policy under European legal and ethical constraints. It operationalises the principle of data minimisation by ensuring that only the information necessary for editorial, regulatory, or analytical purposes is disclosed. At the same time, it preserves the ability to evaluate complex quota definitions that depend on personal attributes which cannot lawfully or ethically be exposed. Implementing this distinction requires more than a technical design choice. It is precisely the challenge addressed by legal, organisational, and semantic alignment under the European Interoperability Framework. The system must be able to lawfully access authoritative data sources, design an organisational workflow that produces a determinate evaluative outcome, and communicate that outcome back into a shared data space using semantics that can be consistently interpreted by diverse actors, including broadcasters, curators, researchers, and media authorities. In the Slovak context, this workflow is deeply intertwined with rights management. The national data sharing space is organised around SOZA, the collective management organisation with legal competence to identify musical works and connect them to living rightsholders and their heirs. Personal characteristics of composers—such as place of birth, nationality, residence, or ethnicity—are strictly protected under the General Data Protection Regulation and are not accessible for disclosure. As a result, while the evaluative logic is conceptually 35 straightforward, its practical implementation is necessarily mediated by institutional trust and competence. At a high level, the internal evaluation proceeds through a sequence of controlled matches. A sound recording is identified and linked to the musical work it embodies; the work is associated with its composer or composers; and the system evaluates whether any of the relevant personal or work-level characteristics satisfy the applicable quota definition. If at least one criterion is met, the recording is marked as eligible for the purposes of the local content quota. Crucially, the reason for eligibility is never exposed. A composition may qualify because the composer was born in Slovakia, because the composer resides there, or because the lyrics are written in the Slovak language. If any of these conditions are satisfied, all recordings of works by that composer—including co-authored works—are treated as eligible, without disclosing which condition applied. The result of this internal evaluation is exposed through a simple property at the level of the recording. For example, a recording may be labelled as heritage of Slovakia when it qualifies under the national quota, or as heritage of Slovaks when eligibility is based on linguistic intelligibility for Slovak speakers as an ethnolinguistic group. This modelling choice deliberately abstracts away from individual identity attributes while retaining policyrelevant meaning. It allows quota evaluation to operate at the level of cultural artefacts rather than persons. Language of lyrics occupies a particular position within this framework. Unlike personal attributes, language is an audible and editorially relevant characteristic of a recording, yet it remains culturally mediated rather than strictly objective. In SKCMDb, lyrics are treated as Slovak when they are intelligible to a native Slovak speaker, even if they are performed in dialectal or archaic forms, as is common in folk traditions. Such determinations may be established by native-speaker curators, performers, or composers. This approach recognises linguistic variation without essentialising identity or excluding historically rooted forms of expression. The is heritage of property used to express these outcomes is defined in the ECCCH Heritage Digital Twin Ontology33, which subclasses CIDOC CRM and is widely used in museum and heritage contexts. In SKCMDb, this property—also used under the alias local to—represents a form of community stewardship governed primarily by ethical frameworks such as CARE, rather than by legal entitlement alone. In the Hungarian replication, the same property is used to refer not only to Hungarians as a national group, but also to linguistically distinct communities such as Székely or Moldavian Hungarian speakers in present-day Romania. A Szekler folk song may thus be treated as part of the Hungarian national quota for policy purposes, while retaining a more precise ethnolinguistic designation for ethnomusicological analysis. The same abstraction is applied at the level of nation-states. A recording is treated as heritage of or local to Slovakia or Hungary if it meets the respective national quota regulations. This modelling choice enables the computation of statistical indicators—such as the proportion of locally relevant repertoire in charts or playlists—without exposing personal data or identity categories. It also allows the same underlying evaluation logic to support multiple 33Heritage Digital Twin Ontology (HDTO) – First Draft (ECHOES Ontology Task Force 2025) 36 policy objectives, including radio and television quotas, festival programming diversity, and international initiatives such as gender equality pledges. It is important to note that the impact of the General Data Protection Regulation on the cultural heritage, music, and digital humanities sectors extended far beyond the specific context of diversity quotas. While GDPR contains differentiated provisions for libraries, archives, and other GLAM institutions, its introduction nevertheless came as a structural shock to the sector. Long-standing practices of metadata publication, authority sharing, and collaborative documentation—often developed in good faith and under earlier legal regimes—suddenly became legally ambiguous or non-compliant. This applies in particular to retroactively affected archival materials and to cross-institutional authority initiatives, such as shared name files or federated registries, which rely on the controlled exchange of personal data. Within this context, the architecture developed for SKCMDb supports not only policy evaluation, but also institutional compliance and remediation. By enabling the lawful use of GDPR-protected data within trusted environments to correctly link agents to archival, library, museum, and rights registry holdings, the system helps participating institutions to repair metadata, clarify authorship and neighbouring rights relationships, and address potential moral rights issues. Crucially, this work remains internal to competent institutions, while its outcomes—such as corrected links, clarified work–recording relationships, or eligibility evaluations—can be safely exposed at an abstracted level. In this sense, the approach taken here does not merely limit disclosure to avoid legal risk. It creates the conditions under which heritage institutions may, after careful analysis, increase the educational, research, or public visibility of their holdings in a legally and ethically defensible manner. Rather than treating GDPR as an external obstacle to cultural data work, the system incorporates it as a design constraint that, when properly addressed, enables more responsible sharing, clearer rights attribution, and more sustainable interoperability across the music and heritage sectors. By design, this approach prevents the system from becoming a tool for profiling or surveillance. Editors and analysts receive determinate, interpretable results, while the underlying personal data remains protected within competent institutions. In this way, diversity goals are operationalised not through the exposure of identity, but through the careful design of evaluative workflows that respect legal constraints, ethical commitments, and the complex social realities of European cultural production. From a policy perspective, the Finno-Ugric Data Sharing Space functions as a subsidiarity and epistemic-justice stress test for European data governance concepts. Unlike the Slovak or Hungarian cases, it operates largely outside state-scale cultural infrastructures and engages communities whose heritage has historically been documented, classified, and interpreted through external—often post-imperial—institutional frameworks. This makes it particularly relevant for assessing whether European principles such as federation, nonextractive reuse, governance-by-design, and respect for cultural and linguistic diversity can be operationalised in low-scale cultural ecosystems. 37 Figure 7: See our original poster in Digital Humanities in the Nordic and Baltic Countries (DHNB 2025), Tartu, 5-7 March 2025, and the subsequent paper in the following footnote. At the same time, the turn toward Finno-Ugric heritage was motivated by a pragmatic methodological consideration. While the Slovak and Hungarian implementations aimed for broad coverage across hundreds of thousands of works and recordings, such scale makes it difficult to observe, test, and refine governance and modelling assumptions in a controlled manner. By contrast, Livonian and related Finno-Ugric repertoires can be described using hundreds rather than hundreds of thousands of items. This reduced scale enables exhaustive modelling, close inspection of provenance and rights statements, and direct community engagement, providing a conceptually tractable environment in which architectural and governance choices can be stress-tested before being applied to larger national or pan-European systems34. In this sense, the Finno-Ugric module is neither peripheral nor exceptional. It functions as a conceptualand methodological laboratory for European data-space design, demonstrating how principles developed under conditions of maximal institutional fragmentation and linguistic diversity can inform the construction of scalable, trustworthy infrastructures in more complex cultural ecosystems. By enabling communities to participate in the repair, contextualisation, and reuse of authoritative cultural data without recentralising control, the module aligns European data-space logic with commitments to non-discrimination, proportionality, and fundamental cultural rights. 34See our accepted paper in preprint: Federating Open Knowledge through Wikibase: The Case of The Finno-Ugric Data Sharing Space and the original poster presentation A Finno-Ugric Data Sharing Space (Daniel Antal et al. 2025; Dániel Antal et al. 2025) 38 Application Layers and System Architecture The layered system architecture of SKCMDb is a direct consequence of the federated governance model described in the preceding sections. The separation between data stewardship, interoperability, public access, and analysis is not merely a technical design choice, but an operationalisation of institutional competence, legal responsibility, and subsidiarity. In particular, it reflects the need to support policy-relevant evaluation and analytical reuse while ensuring that sensitive data remains under the control of the institutions legally entitled to process it. At the foundation of the architecture is a private or trusted layer, operated by institutions with formal legal competence over authoritative data. In the Slovak case, this layer is anchored in the systems of the collective management organisation SOZA and, where relevant, other trusted institutional partners. This layer contains detailed information on musical works, rightsholders, and personal attributes that may be necessary for internal evaluation, rights clearance, or metadata repair, but which are protected under data protection law. Access to this layer is governed by contractual, legal, and organisational safeguards, reflecting the governance arrangements established through the national Memorandum of Understanding described in Section . Its contents are never exposed directly to external users or applications. The layered system architecture of SKCMDb is a direct consequence of the federated governance model described in the preceding sections. The separation between data stewardship, interoperability, public access, and analysis is not merely a technical design choice, but an operationalisation of institutional competence, legal responsibility, and subsidiarity. In particular, it reflects the need to support policy-relevant evaluation and analytical reuse while ensuring that sensitive data remains under the control of the institutions legally entitled to process it. At the foundation of the architecture is a private or trusted layer, operated by institutions with formal legal competence over authoritative data. In the Slovak case, this layer is anchored in the systems of the collective management organisation SOZA and, where relevant, other trusted institutional partners. This layer contains detailed information on musical works, rightsholders, and personal attributes that may be necessary for internal evaluation, rights clearance, or metadata repair, but which are protected under data protection law. Access to this layer is governed by contractual, legal, and organisational safeguards, reflecting the governance arrangements established through the national Memorandum of Understanding described in Section . Its contents are never exposed directly to external users or applications. Behind the scenes, the trusted private layer performs metadata reconciliation, linking, and repair tasks using AI-assisted workflows within a data sharing space built on a knowledge graph. This model was chosen because it preserves full human control over both data sharing and inference: institutions retain authority over what data is processed and disclosed, while any inferred relationships—such as links between a musical work and its recorded fixations for royalty allocation—remain transparent, traceable, and auditable. By embedding AI within a governed knowledge graph rather than opaque pipelines, the architecture 39 ensures that automation supports, rather than replaces, institutional responsibility, legal accountability, and human oversight35. 8. The use, development and governance of artificial intelligence (AI) systems should foster human creativity through a fair human-centric and rights-based approach. It should: respect cultural rights, accessibility, inclusivity and cultural diversity; develop and promote discoverability of European, national and local content; foster competitiveness; counter digital divides; and foster digital inclusion. We commit to: • Promoting human creation and European cultural and linguistic ligital sovereignty, and addressing ethical risks of biases and cultural homogenisation. • Protecting intellectual property rights, by addressing the impacts of AI on creators’ remuneration, while embracing innovation. Draft Joint Declaration “Europe for Culture — Culture for Europe” (European Parliament, Council of the European Union, and European Commission 2025) The following subsection documents how the private or trusted layer of the observatory was implemented in practice in the Slovak pilot. Rather than proposing a general legal model, it describes the concrete data protection reasoning, lawful bases, safeguards, and governance mechanisms adopted by SOZA and its partners to enable authority control and controlled data sharing in compliance with EU data protection law. It is relatively straightforward to replicate in another EU country, because GDPR applies directly in the entire European Union. Outside of the European Union, significant changes may be necessary. Public-private governance and data protection Prior to the actual establishment of the private or trusted layer as the first layer, data protection challenges needed to be addressed. SOZA collects and processes the personal data of its members for the purposes of collective management. Such collection and processing are based on consent. Although the concept of “collective management” as a lawful basis is sufficiently broad, for reasons of transparency and legal certainty SOZA considered it necessary to identify a new lawful basis for the further processing of personal data within the context of the SKCMDb. Initially, SOZA prepared a consent-based participation scheme. However, due to the large number of members and the low response rate to participation requests, it became necessary to identify an alternative lawful basis for the intended processing. Consequently, a legitimate interest was selected as the lawful basis for further processing. In this context, a legitimate interest assessment, in the form of a balancing test, was required and prepared. 35See more policy context in our Green paper, and more technical details in the Open Music Observatory technical documentation (Daniel Antal 2024a, 2025d). 40 The core of this balancing test36 consisted of assessing the potential impact of further processing of personal data on the rights and freedoms of the data subjects, namely SOZA’s members. If the potential impact on these rights and freedoms were to override SOZA’s legitimate interest, legitimate interest could not serve as a lawful basis for the intended further processing. The personal data held by SOZA that is crucial for the proper functioning and establishment of the SKCMDb was divided into two groups, depending on whether the data would be made publicly accessible or accessible upon request to selected subjects. The categories of personal data concerned include name, surname, pseudonym, date of birth, place of permanent residence, and sex. Name, surname, and pseudonym are made publicly accessible, while date of birth, place of permanent residence, and sex are accessible upon request to selected subjects. This division of personal data into two tiers of access—public and upon request—plays a significant role in the management and protection of personal data. In this context, maintaining control over the data and its extraction is crucial for SOZA. Based on these tiers of access, users of the SKCMDb can also be divided into two groups: data contributors and data extractors. Data contributors provide personal data, thereby contributing to the content of the SKCMDb and improving its quality. Data extractors exclusively extract data from the SKCMDb, either from the publicly available layer or from the upon-request layer. It should be noted, however, that data contributors also act as data extractors with respect to each other’s data. Data contributors include SOZA, HC, HF, and SNK, all of which are signatories to the second Memorandum of Understanding with Reprex, the technical data and knowledge processor is concluded, among other purposes, to enable controlled and legally sound data sharing37. This structure is very similar to the first project of the Copyright Infrastructure Task Force introduced in Section . Data extractors include all data contributors, as well as various music streaming platforms, online knowledge databases, encyclopaedias, and similar services. SOZA’s legitimate interest was identified as including the following objectives: • improving and streamlining the performance of collective rights management carried out by SOZA for its members; • increasing the accuracy and availability of information about the musical works of SOZA’s members; • promoting Slovak music, musical works, musical recordings, and knowledge about Slovak music by making them more easily accessible and searchable; and 36The balancing test was conducted in accordance with Article 6(1)(f) of Regulation (EU) 2016/679 (General Data Protection Regulation, short: GDPR), which permits the processing of personal data where it is necessary for the purposes of the legitimate interests pursued by the controller, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. (European Parliament and Council 2016) 37Memorandum o porozumení vo vzťahu k Slovenskej súhrnnej hudobnej database - [Memorandum of Understanding in relation to the Slovak Comprehensive Music Database] (SOZA, Hudobné centrum, Slovenská národný knižnica, Hudobný fond and Reprex) 41 Interpretation limits and policy relevance The purpose of this case study is not to assess compliance by individual broadcasters, nor to evaluate the effectiveness of Slovak cultural policy. The indicators presented are descriptive, not normative, and they do not imply causality. Their function is to demonstrate that diversityand locality-related metrics can be computed in a manner that is auditable, reproducible, and compatible with European data protection and non-discrimination principles. From a policy perspective, the case study illustrates how authoritative industry data, rightsmediated evaluation, and federated data governance can be combined to support evidenceinformed discussion without creating new surveillance or enforcement mechanisms. From a methodological perspective, it shows that the same infrastructure can support both finegrained microdata curation and high-level statistical aggregation, depending on the level at which questions are asked. In this sense, the charts analysis serves as a proof of implementation rather than as a standalone analytical result. It demonstrates that the SKCMDb architecture is capable of translating abstract policy criteria into computable indicators, while preserving institutional autonomy, protecting sensitive data, and remaining interoperable within a European data space. Discussion and Outlook This paper set out to address a persistent gap between the ambitions of diversity-oriented cultural policy and the practical realities of its implementation in contemporary music ecosystems. Through the development and empirical demonstration of the Slovak Comprehensive Music Database, embedded within the Open Music Observatory framework, we have shown that this gap is not primarily a matter of regulatory design or editorial goodwill, but of missing data infrastructures capable of translating policy criteria into computable, ethically governed outcomes. A central contribution of this work lies in reframing local content quotas and diversity targets as information design problems rather than enforcement challenges. By distinguishing clearly between cultural artefacts and persons, and by separating internal evaluation from external disclosure, the SKCMDb approach demonstrates that complex eligibility rules can be operationalised without exposing sensitive personal data or violating principles of nondiscrimination. This reframing is particularly important in the European context, where cultural policy objectives must coexist with strong data protection regimes and fundamental rights protections. The case study based on official Slovak music charts illustrates how this approach functions in practice. By relying on an authoritative, neutral reference corpus, the analysis avoids the pitfalls of monitoring or evaluating individual broadcasters, while still demonstrating how policy-relevant indicators can be computed reproducibly and transparently. The resulting indicators are not instruments of enforcement, but shared points of reference that can support voluntary compliance, editorial reflection, and evidence-informed discussion across 48 the music ecosystem. In this sense, the charts analysis serves as a proof of implementation rather than a policy verdict. At the same time, the broader architecture of SKCMDb highlights the importance of subsidiarity and pluralism in cultural data governance. The Slovak and Hungarian implementations, together with the Livonian and Karelian community-curated databases, demonstrate that methodological coherence does not require uniform analytical outputs. National broadcast monitoring, ethnomusicological competence questions, and community heritage stewardship can coexist within a shared framework, provided that governance, semantics, and responsibilities are clearly articulated. This pluralistic design reflects both the diversity of European cultural production and the institutional realities of the cultural sector. Several limitations of the present work should be acknowledged. First, the indicators demonstrated here are necessarily reductive abstractions of complex cultural phenomena. They do not capture qualitative dimensions of musical innovation, artistic value, or audience engagement, nor do they address causal relationships between policy interventions and cultural outcomes. Second, the reliance on authoritative institutional data implies a dependency on existing infrastructures, which may vary in completeness and accessibility across countries and sectors. Finally, while the approach is designed to be extensible, its successful replication depends on the willingness of competent institutions to engage in shared governance and to invest in sustainable data stewardship. Despite these limitations, the implications of this work extend beyond the immediate Slovak context. The methodological and architectural principles outlined here are applicable to other cultural domains and policy areas in which diversity, representation, and fairness intersect with large-scale data processing. In particular, they offer a pathway for integrating cultural policy objectives into algorithmic environments—such as recommender systems and analytics platforms—without reproducing the extractive or surveillance-oriented practices often associated with global digital platforms. Looking forward, this work contributes to the ongoing development of the Open Music Observatory as a prototype for a future European Music Observatory. Its diversity pillar, of which SKCMDb constitutes a substantial part, demonstrates how European values of data governance—subsidiarity, proportionality, data sovereignty, and ethical stewardship—can be operationalised in practice. The inclusion of Finno-Ugric musical heritage, extending beyond the geographical boundaries of Europe, further underscores that “European” in this context denotes a governance philosophy rather than a territorial limitation. Future research and development efforts will focus on expanding the range of indicators, refining rights-aware modelling, and exploring integrations with emerging AI governance frameworks. In doing so, the aim is not to replace editorial judgement or cultural expertise, but to augment them with infrastructures that make diversity goals computable, auditable, and actionable under real-world conditions. By treating cultural policy as a shared infrastructural challenge rather than a zero-sum regulatory contest, the approach presented here offers a constructive path toward more inclusive, resilient, and transparent cultural ecosystems in Europe and beyond. 49 References Antal, Daniel. 2020a. “Feasibility Study on Promoting Slovak Music in Slovakia & Abroad.” https://doi.org/10.5281/zenodo.6427514. ———. 2020b. “Projektová štúdia propagácie slovenskej hudby na Slovensku a v zahranicí [Feasibility Study On Promoting Slovak Music In Slovakia & Abroad].” Translated by Dáša Bulíková. https://doi.org/https://doi.org/10.5281/zenodo.6427556. ———. 2024a. “Open Music Observatory.” Digital Music Observatory. https://doi.org/10. 5281/zenodo.16539570. ———. 2024b. “Building a Music Data Sharing Space with Wikibase.” Open Music Observatory. https://doi.org/10.5281/zenodo.17078911. ———. 2024c. “Trustworthy AI and Data-Sharing Spaces for the Slovak Music Centre. 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These files are not available directly, but the persons’ data was worked into the Slovak Comprehensive Music Database. Some of this personal data is also available on an opt-out basis to support SOZA’s collective rights management activities, and reduce the cost and potential error rate of distributing the artist’s royalties. The opt-out data is handled by a separate agreement between SOZA and Reprex. Generally, names are treated in two ways: in the graph database, they are used as a label of the graph node that represents the artist; and either as a full name, or as given and surname, they are added separately to this graph. The label is always a preferred name, whenever possible, based on our MoU with the Slovak national library, we use the preferred name of SNK’s authority file. In the alias field, we collect known surface forms of the name to match music service or bibliographical records. For example, the 19th century composer’s name is often spelled as Franz Liszt,Liszt Ferencz (contemporary 19th century spelling)or Liszt Ferenc, and as Liszt, F. Liszt was one of the most famous musicians of the Austro-Hungarian dual monarchy, and he lived and worked in the current territory of the Slovak Republic, Hungary, and Austria. According to the customs of Austria-Hungary, he used his name in a German and Austrian form. Currently, the Slovak national authority files and the German authority files use Liszt, Franz as the preferred name. The Hungarian, Estonian, Czech, and Lithuanian national systems prefer the Hungarian Liszt, Ferenc version. The Russian national library uses Liszt, F, or its Cyrillic transliteration. In the 21 century, it is less usual to have translated given names, however, it remains a fact that Hungarian names, including minority Hungarian names in Slovakia are following the Eastern name order: Kurtág Ferenc, which would be Ferenc Kurtág in the Western name order, and libraries in Hungary and most of the world would use the Kurtág, Ferenc unambiguous ordering. We see two modelling solutions for this problem, explicitly writing in Ferenc as a given name, and indicating that its historical form is Ferencz and historically it was often translated to Franz, and treat Liszt as a surname. This aligns most with the generally used FOAF ontology. The other solution, which may replace or complement the previous solution is the use of several labels and aliases. Our system has labels for every language, therefore, in the Slovak interface, the main label is Liszt, Franz, while in the Hungarian it is Liszt, Ferenc. In this case, for interoperability between Slovak and Hungarian sources, we use Liszt, Franz as a preferred label on the Slovak interface, and Liszt, Ferenc as an alias (alternative name); in the Hungarian language interface, we do the opposite. In ontological terms, “Liszt, 54 Franz”@sk is the rdfs:label for Slovak language use and “Liszt, Ferenc”@hu is the rdfs:label for Hungarian language use. Last but not least, artists may chose to detach their private and public personas and use pseudonyms. In this case, unless we are explicitly consented, we only reveal the pseudonym of a living artist. This aligns with the practice of authority files in national libraries, CISAC and IFPI affiliates. Table 1: Given name variable name given_name description Given name of the person consenting ontological alignment omo:P22 - aligned with FOAF note Table 2: Surname variable name surname description Family name of the person consenting ontological alignment omo:P22 - aligned with FOAF note Location and nationality We do not collect, unless consented, data on ethnicity. However, for the purpose of Slovak cultural policy and media regulation, we need to know if the works of a person meet the local content guidelines, which is derived from the nationality, place of birth or residence status of the artist. As explained in Section , by principle, we do not expose this sensitive data, but we infer if the person’s works meet the local content regulation. • In case of people, we create a special location property which states that the person is local to Slovakia. • In the case of works, we apply a special property, is heritage of Slovakia; or is heritage of Slovaks. Historically, many Czech, Austrian and Hungarian nationals lived in Slovakia, and currently the Slovak Republic provides temporary protection to many Ukrainian (and other) nationals. Regardless of ethnicity, these people may fall under the local content guidelines, and for this media regulatory purpose we claim that they are local to Slovakia. We use qualifiers to ensure that this is not part of their personal identity, but a legal fact about their compositions. In the case of works, a work and its recorded fixation meets the Slovak local content regulation if it uses the Slovak language, or it is composed by a person who meets the local 55 content regulation’s definitions, regardless of ethnicity or nationality. When we claim that a work is a heritage of “Slovaks”, we use it in a narrow sense: for composed works, we refer to Slovaks as an ethnolinguistic group who use the Slovak language. The heritage of “Slovakia” is any work composed by qualifying persons. Last, but not least, non-vocal authentic folk music of Slovaks is also a heritage of Slovakia. In this case, to avoid misunderstandings, we use “authentic Slovak folk music” as a genre, i.e., a property of the music, and not its unknown composer or performer. Table 3: City variable name adress_city description The city where the person currently resides ontological alignment location omo:P22 - aligned with DCTERMS, RiC, CIDOC note Table 4: Date of birth variable name date_of_birth description Date of birth ontological alignment date of birth omo:P22 - aligned with FOAF with qualifier note Table 5: Country of birth variable name country of birth description The country where the person was born ontological alignment location omo:P73 - with qualifier, aligned with DCTERMS, RiC, CIDOC note An auxilliary variable to establish is heritage of/local to Slovakia, i.e., if the person’s compositions belong to the Slovak local quota. Table 6: Lived in Slovakia variable name has_lived_in_Slovakia description The person at some point lived in Slovakia note An auxilliary variable to establish is heritage of/local to Slovakia, i.e., if the person’s compositions belong to the Slovak local quota. 56 Table 7: nationality variable name nationality description The person’s nationality ontological alignment location omo:P73 - with qualifier, aligned with DCTERMS, RiC, CIDOC note An auxilliary variable to establish is heritage of/local to Slovakia or one of its regions, i.e., if the person’s compositions belong to the Slovak local quota. Because the nationality connects the artist with a geopolitical entity, we use a special form of location; the ethnonym of “Slovaks” is reserved for the Slovak ethnolinguistic community. Table 8: Place of birth variable name place_of_birth description The person at some point lived in Slovakia note An auxilliary variable to establish is heritage of/local to Slovakia or one of its regions, i.e., if the person’s compositions belong to the Slovak local quota or to a locally curated music collection. Table 9: Sex assigned at birth variable name sex_at_birth description The sex assigned at birth: female or male. ontological alignment sex or gender omo:P23 - aligned with Wikidata, SDMX. note SKCMDb can handle non-binary gender identities, but SOZA, following Slovak administrative practice, only has the judicially recognised sex availalbe; the artist can ask the variable to be changed. Table 10: IPI_name_number variable name IPI_name_number description Interested Parties Information Name Code ontological alignment sex or gender omo:P23 - aligned the CisNet database’s internal, globally harmonised proprietary identifier. note A unique identifying number assigned by the CISAC database to each Interested Party in collective rights management. An artist may have multiple IPI numbers for multiple pseudonyms or name variations. 57 Release Name variable name release_title description Title of the release containing the recording ontology alignment title of the release entity notes Refers to the release, not the recording Normalised Release Name (Identifier-style Alias) variable name normalised_release_title descriptionDeterministically normalised alias of the release name ontology alignment — notes Derived from the release name by applying ASCII-only, uppercase normalization for identifier-style matching and reconciliation. This variable is an alias of the release name, not a distinct release entity or title statement, and carries no ontological role. It is intended exclusively for technical matching, joining, and comparison, not for presentation or authoritative naming. Release Type variable name release_type description Classification of release as album, single, or compilation ontology alignment Maps to subclasses of release in the Annex (single,album, compilation) notes Follows the release categories used in Spotify metadata UPC or EAN The Open Music Europe – ISRC-Sampled Sound Recording Metadata does not contain release identifiers, and not in all cases in the smaller datasets. variable name upc description Universal Product Code or European Article Number identifying the release ontology alignment UPC or EAN notes Identifies the release entity, not the recording 64 Label Name We provide this information when it is given. It is not provided in the Open Music Europe – ISRC-Sampled Sound Recording Metadata, and not in all cases in the smaller datasets. variable name label_name description Label or imprint text supplied via Spotify metadata ontology alignment record label notes This is a descriptive imprint only; rights-bearing organisations must be identified separately Label Identifier (Curated) This information is not given in the case of the Open Music Europe – ISRC-Sampled Sound Recording Metadata, and not in all cases in the smaller datasets. 65