General-purpose model providers in the European Union must now publish a summary of their training content

2025-08-02EU Policy

Regulation (EU) 2024/1689 (Artificial Intelligence Act), Articles 53, 111(3) and 113(b), obligations of providers of general-purpose AI models applicable from 2 August 2025; European Commission, General-Purpose AI Code of Practice (10 July 2025); European Commission, Explanatory Notice and Template for the Public Summary of Training Content for general-purpose AI models (24 July 2025)

Chapter V of the Artificial Intelligence Act, on general-purpose models, applies from 2 August 2025 under Article 113(b), with the exception of Article 101 on fines. Article 53(1) requires every provider of a general-purpose model to keep technical documentation "including its training and testing process"; to give information and documentation to providers that integrate the model, "[w]ithout prejudice to the need to observe and protect intellectual property rights and confidential business information"; to "put in place a policy to comply with Union law on copyright and related rights," including reservations of rights under Article 4(3) of Directive (EU) 2019/790; and to "draw up and make publicly available a sufficiently detailed summary about the content used for training" on a template from the AI Office. Models released under a free and open-source licence are exempt from the first two duties only, and not if they carry systemic risk. Under Article 111(3), providers whose models were placed on the market before 2 August 2025 have until 2 August 2027. The Commission published the voluntary General-Purpose AI Code of Practice on 10 July 2025, with chapters on transparency, including a model documentation form, copyright, and safety and security, and on 24 July 2025 adopted the mandatory template, under which the summary lists the main data collections and explains other sources.

What it changesThe training content summary is a mandatory publication for every general-purpose model placed on the European Union market, and anything it discloses about data selection, filtering, deduplication, synthetic data generation or handling of opt-outs is prior art from the day it is posted and no longer a trade secret. Patent counsel should see each summary before it is published. Any pipeline invention the summary would reveal should be filed first, and the summary should be written at the level of generality the template requires and no lower. The technical documentation and downstream information duties do not publish anything, but documentation handed to integrating providers travels under contract, so the confidentiality terms in those agreements need the same review as a license. For models already on the market the 2027 deadline leaves time to file on pipeline inventions that the first summary would expose.

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Burbage Law is the practice of Jon Burbage, a registered patent attorney. 342 United States patents have issued from applications he wrote; the full list is on the Patents page. More about Jon Burbage.

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