Non-EU vendorE-learning AuthoringHeadquarters: GB

Create (formerly Elucidat): sovereignty score and 8 European alternatives

Elucidat is a cloud-based authoring tool for large learning teams, now marketed by Confirm as Create (formerly Elucidat). It offers AI-generated course outlines, PowerPoint import, templates, in-app review, brand and style locking, and translation into more than 75 languages with glossary enforcement. A built-in image library, text-to-speech narration and learner analytics on progress, completion and pass rates are included. Courses reach learners through a web link or as a SCORM file in any LMS, and the tool feeds content to Confirm's Learn:Go learning platform.

Learning Pool announced its acquisition of Elucidat in October 2025; Learning Pool has since been renamed Confirm. Elucidat was founded in Brighton, and Confirm lists the UK as its headquarters, with offices in Derry, Brighton, Delaware and San Francisco. The UK is not an EU member state, and the product is proprietary software. The product pages do not state where content is hosted, so ask for the hosting region and sub-processors in the contract.

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Sovereignty score

32 / 1000 = high exposure
100 = sovereign

Jurisdiction SOV-250
Headquartered outside the EU (GB)
Data residency SOV-30
No hosting in Europe (UK)
Cryptographic key sovereignty SOV-340
Key management with a non-European vendor
Freedom from lock-in SOV-640
Closed source: switching requires data migration
Source & runtime sovereignty SOV-4 · SOV-630
Closed source, runtime with the vendor

SOV codes: the matching objective in the European Commission's Cloud Sovereignty Framework. Official source

How the score is calculated

Facts and evidence

Last checked October 9, 2026

Headquarters	GB (OTHER)Verified by hand
EU adequacy decision	Yes — found adequate by the European CommissionVerified by hand
Sovereignty model	Vendor-hosted (non-EU)Verified by hand
Data hosting	UKVerified by hand
Open-source	NoVerified by hand
GDPR-compliant	YesVendor-stated
Category	E-learning Authoring
Type	Product
Website	confirm.com ↗

How we verify · Something wrong? Suggest a correction

Top EU-based & GDPR-compliant alternatives to Create (formerly Elucidat)

The European alternatives to Create (formerly Elucidat) come from our knowledge base of over 6,800 vendors. We only list vendors headquartered in the EU or the EEA; fully European-owned vendors rank before vendors with a foreign owner. For each alternative you see the country, the open-source status and a short description.

Score per alternative: 0 = high exposure, 100 = sovereign

34 European E-learning Authoring vendors are in the catalogue. View the whole category · Submit an alternative · View category on the map

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Why digital sovereignty matters with Create (formerly Elucidat)

Create (formerly Elucidat) is headquartered in GB, outside the EU. Contracts and data therefore also fall under non-European law. The GDPR applies through contractual terms, but in a conflict with local legislation you have less certainty than with a European vendor.

Create (formerly Elucidat) hosts data outside the EU (UK). Personal data therefore leaves the EU, which requires a transfer mechanism under the GDPR and pulls the data residency score down.

Create (formerly Elucidat) is closed source and hosted by the vendor. The encryption keys and the runtime sit with the vendor and switching requires data migration. Ask about bring-your-own-key, export options and open standards.

What this means for your organisation depends on your whole stack and context. The free assessment weighs Create (formerly Elucidat) together with your other vendors and gives a total score, a heatmap and the main risk drivers.

Frequently asked questions

What is the best European alternative to Create (formerly Elucidat)?

It depends on your use case. Strong EU alternatives to Create (formerly Elucidat) include 360Learning, Attensi and bettermarks. On this page you can compare 8 EU alternatives by jurisdiction, data residency and open-source status.

Are there open-source alternatives to Create (formerly Elucidat)?

Yes. Open-source EU alternatives to Create (formerly Elucidat) include eXeLearning. These keep your data fully under your own control and let you self-host if you want to.

Is Create (formerly Elucidat) GDPR-compliant and where is the data hosted?

Create (formerly Elucidat) is headquartered in GB (OTHER) and hosts data in UK. The vendor states it is GDPR-compliant, but the data falls under non-EU jurisdiction. For full EU data residency the EU alternatives on this page usually offer more certainty.

Details and sources

Verified by handHeadquarters, owner, hosting locations and licence have been checked by us against public sources. Free of charge and for every vendor, not a paid label. Nothing in this knowledge base is taken over automatically. Last checked on October 9, 2026.

Sources

Public sources used in the latest check of this record.

Compliance evidence

The links below point to the vendor's own public documents. We only record what we found: a missing link means "not found publicly", not "not compliant".

No public compliance evidence has been recorded for this vendor yet. Do you know its DPA or subprocessor list? Something wrong? Suggest a correction

Digital sovereignty in E-learning Authoring

E-learning Authoring: E-learning authoring software, interactive content and presentation tools. In this category the choice of vendor determines who has legal access to your data, where that data lives and how easily you can switch later.

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