Jurisdiction(s):
European Union

EU AI Act template: Ambiguous training data disclosure (top-10% domains and 'size' metrics) complicates multi-modal reporting and rights-holder copyright enforcement

Published on: 13 August 2025

Published by an LexisNexis EU Law expert

Legal News

Article summary

The Commission has unveiled a standard form that AI makers falling under the EU AI Act must use to set out the data fed into their systems. Yet the reach of one of its most contentious obligations is still not, as yet, defined.

Under the EU AI Act, creators of general‑purpose models, including OpenAI, Anthropic and Google, must release a ‘sufficiently detailed summary’ describing the training data that were used to train their models.

What counts as ‘sufficiently detailed’ follows a compulsory template issued by the EU executive on 24 July 2025.

Models are built on vast datasets, for which information is often scarce or incomplete in practice.

The summary aims to help parties with a legitimate interest—such as data subjects and rights holders—assert their rights under EU law.

But a fiercely disputed disclosure item in the template—expected to be pivotal to whether rights holders can claim standing in copyright disputes—remains unsettled, and its precise scope is still undefined.

List of data sources

For the first time, AI developers will be obliged to publicly disclose and name the specific sources of the data they collected to train their models...

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