Commission consultation on protocols for reserving rights from text and data mining under the AI Act and the GPAI Code of Practice

Consultation December 1st, 2025 - January 9th, 2026 - The Commission has launched a stakeholder consultation to support the implementation of the AI Act’s obligation for providers of general-purpose AI models to identify and comply with reservation of rights expressed by rightsholders.

Drawing of 4 people in front of a large screen with checkmarks Speech bubbles illustrate stakeholder consultation in AI policy making. The Copyright section of the General-Purpose AI (GPAI) Code of Practice offers providers a pathway to demonstrate compliance with their obligation under the AI Act to put in place a policy to comply with EU copyright rules

The GPAI Code of Practice was approved by the Commission as adequate for the purpose of the AI Act compliance. It includes a commitment for signatories, to identify and comply with appropriate machine-readable protocols used to express rights reservations on top of a commitment to respect robots.txt and subsequent IETF versions of this standard.  

To support the implementation of the AI Act’s obligation and this commitment, the Commission launched a process to facilitate the identification and general agreement on opt-out protocols that can be considered as state-of-the-art, technically implementable, and widely adopted by rightsholders across different cultural and creative sectors (as specified in Measure 1.3. of the Copyright Section of the Code). This process will be organised with the support of the EU Intellectual Property Office (EUIPO) and the close involvement and input of relevant stakeholder groups.

Firstly, the consultation invites rightsholders, GPAI providers, civil society organisations, standardisation bodies, and other interested parties to share their views on the technical feasibility and uptake of different Text and Data Mining (TDM) opt-out solutions (identified in the EUIPO study on development of generative artificial intelligence from a copyright perspective).

Secondly, stakeholders are also invited to express their interest in participating in follow-up workshops to discuss opt-out protocols that the Code signatories and other providers must respect in the context of the AI Act. The Commission will facilitate exchanges between stakeholder groups with to reach a general agreement on a list of such protocols. Signatories to the GPAI Code of Practice (CoP) will be invited by default to these meetings.

Following these discussions, the Commission will publish the list of generally-agreed machine-readable opt-out solutions. This list will be reviewed regularly, at least every two years, in line with the updates to the Code of Practice.

Consultation link