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European Commission Adopted Template for General-Purpose AI (GPAI) Model Providers to Summarise the Data Used to Train Their Model

Created by Frank Ingenrieth | European Commission Reference / Update AI Act Other Document

As of July 24th, 2025, the European Commission adopted the template for GPAI model providers becoming mandatory for new models as of August 2nd, 2025. This template complements the Code of Practice, and related to the obligation of GPAI providers pursuant Art. 53.1 lit. d) AI Act.

TL:DR / Summary

  • European Commission adopted the Explanatory Notice and Template pursuant Art. 53.1 lit. d) AI Act
  • The Template will be mandatory for new models as of Aug 2nd, 2025; for already existing models it will be mandatory no later than Aug 2nd, 2027.
  • The AI Office has powers to monitor and enforce the proper publication of a provider's summary pursuant Art. 53.1 lit. d AI Act, which the EC considers solely met if the template is completed.
  • Non-compliance may accumulate to  fines of up to 3% of the provider’s annual total worldwide turnover in the preceding financial year or EUR 15,000,000 whichever is higher.
  • The Template shall be considered complementing to the Code of Practice (CoP) for GPAI.
  • The Template seeks to prevent unnecessary burdens for SME.

Relation to the CoP for GPAI, Main Contents

The Template complements the CoP for GPAI. While the CoP for GPAI is considered a voluntary tool, the use of the Template is deemed mandatory. The CoP addresses providers' obligations pursuant Art. 53.1 lit c AI Act, whereas the Template addresses obligations pursuant Art. 53.1 lit d AI Act. 

The Template mainly addresses three elements

  • General Information
  • List of Data Sources
  • Relevant Data Processing Aspects

In respect of General Information, the template requires information to identify the provider and model, and information regarding modalities, the size of each modality within broad ranges, as well as general characteristics of the training data.

In respect of List of Data Sources, the template requires disclosure of the main datasets that were used to train the model, a comprehensive narrative of online data being scraped by on behalf of the provider, and for the sake of completeness a narrative description of all other data sources

In respect of Relevant Data Processing Aspects, the template requires disclosure of data processing aspects to enable parties with legitimate interests under Union law to exercise their due rights, e.g., in respect of copyright or removal of illegal content which otherwise might be reproduced and disseminated at scale. .

Balancing of Providers' Interests, Drafting Process, Reflection of needs of SME

The European Commission acknowledges the interests of providers and other parties involved, e.g., in respect trade secrets. Therefore, the template provides for different levels of details depending on the section, data sources, and potentially affected third party interests. 

To ensure different interests will be heard and properly reflected, the Template was drafting in consultation of relevant stakeholders. Following a consultation via Have Your Say with way more than 400 responses, the stakeholder expert group involved in the drawing up of the CoP for GPAI was consulted on the first draft template post the Have Your Say consultation. 

Alongside such business and private stakeholder involvement, the template was also shared with the AI Board and the European Parliament's (IMCO-LIBE Committees) working group on AI. 

Against this background, the European Commission also claims that the Template is designed in a manner preventing unnecessary burdens for SME. 

Legal Status, Consequence of Non-Compliance

Transparency obligations pursuant Art. 53.1 lit. d AI Act are mandatory. The European Commission states in their FAQ, that such transparency obligations may only be met if the Template is being used. 

Even though such obligations will apply to new models by Aug 2nd, 2025 already, enforcement powers of the AI Office become effective with one year delay, i.e., Aug 2nd, 2026. Providers of existing models must comply with the template latest Aug 2nd, 2027. 

If the AI Office will determine non-compliance with applicable transparency obligations pursuant Art. 53.1 lit. d, the European Commission highlights that such non-compliance may lead to fines of up to 3% of the provider's annual total worldwide turnover in the preceding financial year, or EUR 15,000,000, whichever is higher.

Affected AI Act Provision(s) and Terms

Obligations of providers of general-purpose AI models

1.   Providers of general-purpose AI models shall:

[…]

(d) draw up and make publicly available a sufficiently detailed summary about the content used for training of the general-purpose AI model, according to a template provided by the AI Office.

In order to increase transparency on the data that is used in the pre-training and training of general-purpose AI models, including text and data protected by copyright law, it is adequate that providers of such models draw up and make publicly available a sufficiently detailed summary of the content used for training the general-purpose AI model. While taking into due account the need to protect trade secrets and confidential business information, this summary should be generally comprehensive in its scope instead of technically detailed to facilitate parties with legitimate interests, including copyright holders, to exercise and enforce their rights under Union law, for example by listing the main data collections or sets that went into training the model, such as large private or public databases or data archives, and by providing a narrative explanation about other data sources used. It is appropriate for the AI Office to provide a template for the summary, which should be simple, effective, and allow the provider to provide the required summary in narrative form.

  • ‘general-purpose AI model’ means an AI model, including where such an AI model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except AI models that are used for research, development or prototyping activities before they are placed on the market; (Art. 3.63 AI Act)
  • ‘general-purpose AI system’ means an AI system which is based on a general-purpose AI model and which has the capability to serve a variety of purposes, both for direct use as well as for integration in other AI systems; (Art. 3.66 AI Act)
  • ‘provider’ means a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge; (Art. 3.3 AI Act)
  • ‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments; (Art. 3.1 AI Act)
  • ‘training data’ means data used for training an AI system through fitting its learnable parameters; (Art. 3.29 AI Act)
  • ‘AI Office’ means the Commission’s function of contributing to the implementation, monitoring and supervision of AI systems and general-purpose AI models, and AI governance, provided for in Commission Decision of 24 January 2024; references in this Regulation to the AI Office shall be construed as references to the Commission; (Art. 3.47 AI Act)

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