The European Union’s AI Act entered into force in August 2024. In support of the AI Act, the European Commission released its General-Purpose AI Code of Practice (GPAI-CoP), a voluntary tool designed to help providers of general-purpose AI models comply with the AI Act’s obligations, which go into effect on August 2, 2025.
In the GPAI-CoP press release, the EU said it will also soon publish guidelines on key concepts related to general-purpose AI models. The guidelines are initially voluntary and give a first glimpse at how the EU may enforce the AI Act, which becomes enforceable in 2026.
Compliance
The Copyright chapter obligates AI platforms to commit to drawing up, keeping up-to-date and implementing a copyright policy, to commit not to circumvent effective technological measures against piracy, and to exclude from their web-crawling websites that make available to the public content and which are, at the time of web-crawling, recognized as persistently and repeatedly infringing copyright and related rights on a commercial scale.
Platform providers must also comply with rights-holder guidelines expressed through robots.txt and rights-expression instructions expressed by other means.
The Transparency section obligates model providers to maintain documentation about their models and make that documentation avaialble to downstream AI providers. They must comply with EU law on copyright and related rights, and in particular to identify and comply with, including through state-of-the-art technologies, a reservation of rights. Signatories commit to drawing up, keeping up-to-date and implementing such a copyright policy. Model documentation must be controlled for quality and to demonstrate compliance with obligations under the AI Act.
In addition to copyright-related matters, the AI Act also regulates the use of biometric information by AI platform providers.
Components of the GPAI-CoP include:
- A Transparency chapter containing a Model Documentation Form which allows providers to easily document the information necessary to comply with the AI Act obligation to on model providers to ensure sufficient transparency.
- The Copyright chapter offers providers practical solutions to meet the AI Act’s obligation to put in place a policy to comply with EU copyright law.
- The Safety and Security chapter is designed to help model providers comply with the AI Act obligations for providers of general-purpose AI models with systemic risk.
Industry advocates speak up
As of this writing, no AI model providers had responded formally to the GPAI-CoP. However, the Computer & Communications Industry Association (CCIA) – whose members include Google, Meta and Amazon – was quick to object to the Code of Practice.
Boniface de Champris, Senior Policy Manager for CCIA Europe, said ” (The) final code of practice for general-purpose AI (GPAI) models … imposes a disproportionate burden on AI providers…” and characterized it as “a regulatory framework rushed through political negotiations.”
He continued, “… (The) copyright section has … disproportionate measures outside the Act’s remit. These include complaint-handling mechanisms, specific requirements for search engines, and vague processes for developing new opt-out mechanisms – all of which create additional legal uncertainty.”
Rights-holders and creators had the opposite view. The International Federation of the Phonographic Industry (IFPI), in a March 2024 statement, praised the EU’s call to responsibility, said:
“The EU AI Act … provides first tools for rightsholders to enforce their rights, (and places) obligations on providers of General Purpose AI (GPAI) to make available a sufficiently detailed summary of the works used for training their models, to retain detailed technical documentation and to demonstrate they have put in place policies to comply with EU copyright law, regardless of where they acquired data or trained and developed their AI models.”
Further reading
The General-Purpose AI Code of Practice. Policy guideline document. July 10, 2025. European Commission
European Approach to Artificial Intelligence. Landing page. Accessed July 15, 2025. European Commission
AI Act. Landing Page. June 13, 2024. European Commission
Artificial Intelligence for Europe. Vision statement – European AI Strategy. April 25, 2018. European Commission
EU orders AI companies to clean up their act, stop using pirated data. Article. July 11, 2025. France 24.
EU AI Act – Joint statement from European creators and rightsholders. Press release. March 14, 2024. International Federation of the Phonographic Industry (IFPI)
AI Act: EU’s final GPAI code imposes disproportionate burden, improvements required. Position statement. July 10, 2025. Computer & Communications Industry Association (CCIA) Europe
Why it matters
The EU’s approach to establishing and manaaging AI policy is necessarily a collaborative effort across the EU government and the governments of EU member states. The approach to artificial intelligence “centers on excellence and trust, aiming to boost research and industrial capacity while ensuring safety and fundamental rights.”
The GPAI-CoP is intended to keep developers of generative artificial intelligence platforms from using copyrighted content without licensing the content from its owners or rights-holders.
While there have been many individual lawsuits by rights-holders in recent years, decisions and policy statements by governmental agencies and regulators are just now beginning to emerge.
Like the EU’s Digital Markets and General Data Protection Regulation before it, the General Purpose AI Code of Practice will be controversial and because it is currently voluntary, will also be subject to change over time. But it’s a start.
