Pope Leo last Friday urged Catholic lawmakers to develop policy
that would provide transparency on the use of AI, and protect families
from the economic, moral, and social harms that might be caused by the
disruptive potential of artificial intelligence.
The
pope warned of “a subtle form of domination when algorithms decide who
is seen” and who is not, “when digital platforms shape public discourse
without accountability, and when the dignity of workers is subordinated
to the optimization of systems.”
The role of
lawmakers, Leo said, is to “encourage scientific and technological
creativity while safeguarding fundamental human rights and freedom,” and
to “protect users from exploitation, preserve personal privacy, ensure
transparency in the use of emerging technologies.”
But
while the pope was talking to lawmakers, he wasn’t just doing so as a
pastor — he is himself a legislator, the lawmaker of the universal
Church, and thus his words of advice might well be taken to apply to the
ecclesial society, and its body of law, as to any other society.
The
territorial state governed by the Holy See - the Vatican City State -
is on the path to legislation concerning AI. In January 2025, a decree
came into effect from the Pontifical Commission for Vatican City State
which created a commission on AI, meant to propose laws for the
regulation on the use of AI with the Vatican City.
The
decree also contained ethical principles for the use of AI, with a
particular focus on avoiding manipulation, being transparent in the use
of AI, and taking care to avoid the creation of social inequalities or
the encouragement of criminal conduct.
Eventual
legislation from the commission — which would be formally approved by
the pope — would impact city state administrators, the Vatican Museums
and gardens, the Vatican health service and court system, police and
firefighters, and property managers, along with other clerical workers
and contractors within the Vatican City State.
But
while that project was already underway when Leo was elected, it could
be seen as a smaller-scale test case for his bigger role, as universal
legislator of the universal Church.
To date, the pope
has not yet indicated that he is considering a revision to the Church’s
universal canon law, in response to the disruptive technology of AI.
But
as AI manifests new challenges for parishes, dioceses, and for the
universal Church, dioceses, especially in the U.S., have already begun
developing policies on the use of AI in their own work.
And other Catholic institutions have begun doing the same, with Catholic Charities USA issuing this month, for example, an “ethics guide” for diocesan Catholic Charities apostolates and their use of AI.
Some
dioceses, however, are likely looking to the Vatican for guidance, or
hoping that the Holy See will promulgate universal laws that give at
least a framework to more local efforts, or that backstop policies which
may not be immediately welcome — however they shake out — among
Catholics with strongly held opinions on the subject.
A thorough regulation of AI in the Church’s life would doubtless touch on many areas of canon law.
To
many Catholics, the most pressing issue for the Church to address is
the use of generative AI in the creation of sacred images, hymn texts,
and especially liturgical preaching. While the topic was not raised in
Pope Leo’s Magnifica humanitas, many
Catholics have noted in recent months the rising prevalence of
AI-generated sacred images in parish or diocesan worship aids or
catechetical material.
And an increasing number of Catholics have
reported to The Pillar in recent
months the experience of hearing homilies delivered in parish liturgies
which bear the distinctive rhetorical patois of AI-generated text.
Given
that liturgical preaching is an act so closely correlated with the
charism and power of sacred orders, it seems an obvious place to begin,
if the pope decided to address the prevalence of AI-generation in sacred
contexts. Revisions to Book III of the Church’s Code of Canon Law, for
example, could specify that since preaching is a human act, a human
being should be the principal author of a text.
Similarly,
there is growing dissatisfaction among a number of Catholics with the
use of “AI slop” in the generation of sacred images — and clearly
disparate expectations between those producing the images in parish and
diocesan images, and those pushing back against them.
Of
particular import on that question is what it means for images of
divine and sacred persons to be created without the involvement of human
beings — especially given the Church’s long history
If
the current dispute over Rupnik-generated images has a lesson, it is
that sacred art matters to people, and how it is created matters to them
— which means that however the pontiff decides to address that, the
conflict over “AI slop” Catholic images is unlikely to resolve on its
own, absent some ecclesiastical guidance on the subject.
Two
AI issues of key importance to Leo seem as relevant to ecclesial life
as to any other sphere of society, and thus of particular import for
legislation — transparency, and AI/human interaction. On the question of
transparency, there is not presently any ecclesial guidance on when
curial or diocesan offices should disclose the use of AI, and existing
diocesan policies do not seem to consistently require it.
But the
guidelines of the Vatican City State, along with other Vatican texts on
the subject, emphasize frequently the importance of transparency about
the use of AI, suggesting that Leo could include in the Church’s on the munus docendi — its teaching function — some regular disclosure in ecclesial documents and policies about the use and scope of AI.
In
addition to transparency, Leo has emphasized the dignity of workers,
and while that issue encompasses a variety of topics, they include a
topic under discussion now — whether employees, students, and others in
Catholic contexts have the right to opt out of AI-interaction, when it
is used in instruction, assessment, the provision of services, or
training.
Leo has been clear that the anthropomorphizing of large
language models poses particular moral and anthropological problems, and
that the contours of engagement of LLMs with people in the course of
work merits particular and ongoing reflection.
As that unfolds, it seems
reasonable to conclude that ecclesiastical authorities will have to
make some judgement about whether engagement with LLMs can be considered
compulsory for ecclesiastical employees and officeholders, and whether
workers whose productivity proceeds at a more human rate because of the
way they choose to make use of AI — or not — will be penalized.
While
those things pertain mostly to ecclesiastical personnel, the place
where LLMs seem most likely to be used in day-to-day diocesan operations
is in the diocesan tribunal, where personnel write voluminous amounts
as they adjudicate marriage cases — petitions for declarations of
matrimonial nullity — and where, in some dioceses, parties and witnesses
are asked to complete lengthy questionnaires.
To
many tribunal personnel, it seems obvious that generative AI has little
place in the legal work of tribunals, but that opinion is not
universally held. And as tribunals face unrelenting pressure to
adjudicate cases quickly, and with limited resources, some tribunal
administrators will, doubtless, hope that AI can help staff do
considerably more, and with less. That could likely lead to pressure on
those personnel, which might well impact the judgments which they are
required to make with genuine moral certitude.
At the
same time, some Vatican officials have speculated that the existence of
AI, and the way its very existence raises questions about the
authenticity of written testimony and party declaration, could spell the
end of written questionnaires in tribunal processes — a result that
would actually lead tribunals to fuller conformity to procedural law.
But
whatever the effects, it seems clear that the Church’s judiciary is a
forum in which proactive regulation could prevent deepening
inconsistency, and the possibility of challenges to the validity of
various legal processes over issues related to AI usage.
From
the start, Leo made clear that his legacy would be shaped largely by
his leadership on the emerging social problems of AI. It remains to be
seen whether he will start with how they impact the internal workings of
ecclesial society.