Many affected parties have criticized the EU’s Code of Practice (CoP) for providers of AI models. 92 responses were submitted during a Spring comment period that ended in June, following the release of the CoP draft in May.
On one side, platform providers said that the draft placed an inordinate burden on AI platform providers including complaint-handling and opt-out mechanisms. On the other side, rights-holders and their advocates said that the CoP lacks mechanisms for rights enforcement and for platform providers to document the sources used to train their models.
July’s final draft contained chapters on transparency and model documentation, but it supplied guidelines to meet copyright, safety and security obligations that many thought still favored the platform providers. Notwithstanding, on August 2, 2025, the transparency obligtions to AI model platform providers went into effect, and the criticism continued.
Continuing documentation issues
On July 30, CISAC, a Paris-based coalition of 39 rights-holder organizations, released a statement lamenting the EC’s missed opportunity to tighten up the transparency obligations.
The statement is excerpted here and the full statement is linked below.
“Despite the extensive, highly detailed and good-faith engagements by rightsholder communities … The result (fails) to provide meaningful protection of intellectual property rights in the context of GenAI and does not deliver on the promise of the EU AI Act itself.
“The deployment of GenAI models and content production systems which also make extensive use of scraping is already underway. The damage to and unfair competition with the cultural and creative sectors can be seen each day.
“We strongly reject any claim that the Code of Practice strikes a fair and workable balance or that the Template will deliver “sufficient” transparency about the majority of copyright works or other subject matter used to train GenAI models. This is simply untrue and is a betrayal of the EU AI Act’s objectives.”
The statement then calls upon the European Commission, European Parliament and Member States to further challenge the process and its outcome.
Further reading
Joint statement by a broad coalition of rightsholders active across the EU’s cultural and creative sectors regarding the AI Act implementation measures adopted by the European Commission. Press release. July 30, 2025. CISAC (International Confederation of Societies of Authors and Composers)
More than 90 recommendations to European Commission’s 2023 anti-piracy consultation. Article. June 13, 2025. by Steven Hawley. Piracy Monitor
Rights-holders call EU’s AI Code of Practice inadequate, with no mechanism to enforce rights. Article. April 1, 2025. by Steven Hawley. Piracy Monitor
Why it matters
CISAC said that “In 2024, the cultural and creative sectors across Europe welcomed the principles of responsible and trustworthy AI enshrined in the EU AI Act, intended to ensure mutually beneficial growth of innovation and creativity in Europe. Today, with the EU AI Act implementing package as it stands, thriving cultural and creative sectors and copyright intensive industries in Europe … are being sold out in favour of … GenAI model providers.”
