New AIPEX Publication – Arbitrary cognitive offloading to GenAI: Does the current policy landscape account for the right to quality education of children and youth in the European Union?
Marit Brademann (University of Edinburgh, extern at the AI Policy Lab)
Abstract
General-purpose generative AI (GenAI) is increasingly used by young learners in the European Union, with 20% of individuals aged 15–29, approximately 15 million people, relying on it for educational tasks such as information retrieval, feedback, or full task delegation. While cognitive offloading is a natural part of human learning, GenAI’s ease of use risks disrupting efficient learning processes, potentially depriving children and youth of their right to quality education, including foundational skills like literacy, numeracy, and critical thinking.
This paper argues that the unmediated use of GenAI in educational settings undermines the right to quality education by interfering with cognitive development. It examines the role of cognitive load, metacognition, and cognitive offloading in learning, linking these concepts to GenAI’s potential to disrupt memory consolidation, problem-solving, and critical thinking. The analysis evaluates the current European policy landscape, focusing on the EU AI Act, OECD Digital Education Outlook 2026, and the European Parliament CULT Committee’s 2026 briefing to assess whether existing hard and soft policies address the cognitive risks of GenAI. While these policies recognize risks, they primarily target AI-enhanced educational technologies rather than general-purpose GenAI, leaving a regulatory gap.
The paper concludes that arbitrary cognitive offloading via GenAI jeopardizes the normative goals of quality education, as defined by frameworks like UNICEF’s and Bloom’s Revised Taxonomy. It calls for a revision of the EU’s normative approach to general-purpose GenAI, emphasizing the need to protect young learners’ right to cognitive development and autonomy.
Keywords: cognitive offloading, metacognition, AI in education, right to education, metacognitive laziness, OECD, EU AI Act, CULT, AI and Human Rights, Governance and Compliance, Human Well-being
…