AI Act explanatory notice and template for the public summary of GPAI training content
Published by the Commission on 24 July 2025, the explanatory notice and template let GPAI model providers publish the 'summary of training content' required by AI Act Article 53(1)(d), setting a common minimum baseline and helping parties such as copyright holders exercise their rights. The template has three sections: general information, list of data sources and relevant data processing aspects, and applies to all GPAI models, including open-source and systemic-risk models. New models must publish it when placed on the EU market; models placed before 2 August 2025 must do so by 2 August 2027.
Timeline
- 24 Jul 2025AuthoritiesCommission publishes the explanatory notice and template
- 2 Aug 2025Obligations for GPAI model providers apply
- 2 Aug 2026AuthoritiesCommission (AI Office) enforcement powers apply
- 2 Aug 2027GPAI models placed on the market before 2025-08-02 must comply
Key facts
- Reference
- Commission Explanatory Notice and Template (24.7.2025)
- Adopted
- 24 Jul 2025
- Published
- 24 Jul 2025
- Status
- In force
- Amendments
- Template under Article 53(1)(d) of Reg (EU) 2024/1689 (AI Act)
- Topic
- Cybersecurity & Data
- Industries
- Cross-sector
Main compliance requirements
Paid members only
The main compliance requirements, applicability questions and penalties are available in the ZC Smart Compliance Hub. Paid members and clients can sign in to the Hub to view them.
Related legislation
- Implements Article 53(1)(d) of Regulation (EU) 2024/1689 (AI Act, as amended by Regulation (EU) 2026/1744). Related: Directive (EU) 2019/790 (Copyright in the Digital Single Market), Copyright chapter of the GPAI Code of Practice, GPAI scope guidelines C(2025) 5045.
Official sources
Explanatory Notice and Template for the Public Summary of Training Content for general-purpose AI models
Full text on EUR-Lex (Commission Explanatory Notice and Template (24.7.2025))