Artificial Intelligence Policy Tracker

Copyright and training-data transparency: AI obligations

Practical requirements extracted from policy instruments, with the source article, the actors they bind, evidence examples and original framework mappings. Legal requirements are marked; everything else is voluntary guidance.

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Legal requirement Copyright and training-data transparency European Union

Meet general-purpose AI model provider obligations

EU AI Act · Article 53 and Annexes XI–XII

Providers of general-purpose AI models must keep technical documentation (Annex XI), provide information to downstream providers integrating the model (Annex XII), put in place a policy to comply with EU copyright law including the text-and-data-mining opt-out, and publish a sufficiently detailed public summary of training content using the Commission's template. Free and open-source models are exempt from the first two duties unless they present systemic risk. Adherence to the General-Purpose AI Code of Practice can demonstrate compliance.

Pending review (a factual check against the official source, not a legal review) Applies from 2 Aug 2025

Frequently asked questions

What is an obligation on this site?

A single practical requirement pulled out of an instrument and stated on its own: keep a risk management system, log incidents, document training data, provide human oversight, and so on. Each one cites the article or section it comes from so you can check it against the source.

Does a voluntary obligation have legal force?

No, and every obligation is labelled either a legal requirement or voluntary guidance. Voluntary items still matter in practice, because procurement questionnaires and auditors ask about them, but only the binding ones carry legal consequence.

How do I find the obligations that apply to my organisation?

Filter by jurisdiction, category, actor, sector or use case. The applicability check asks a short set of questions and returns the duties that may reach you. It is an educational screen, not a legal determination, and it says so.

Why do some instruments have no obligations listed?

Because nobody has broken them out yet. Most instruments are recorded at summary level first; obligations are added jurisdiction by jurisdiction. The coverage and open-gaps pages publish exactly what is missing rather than hiding it.