# The EU AI Act and training data

URL: https://aidataforsale.com/ai-data-law/eu-ai-act-training-data
Publisher: AI Data For Sale (Marketing Signals Ltd)
Updated: 2026-11-10

What the EU AI Act requires of general-purpose AI providers on training data: the public summary, copyright policy and opt-outs, with dates and seller impact.

How the EU AI Act's general-purpose AI rules reach training data, including data licensed from US companies.

## In short

- Obligations for providers of general-purpose AI models applied from August 2, 2025.
- Providers must publish a summary of training content using a template the European Commission published in July 2025.
- Providers must have a copyright policy, including respecting text and data mining opt-outs.
- The AI Office's enforcement powers, including fines, apply from August 2, 2026.

## Who it applies to

The AI Act's rules on general-purpose AI (GPAI) models apply to providers placing those models on the EU market, wherever they are based. A US lab whose model is offered in the EU is covered. A US company that licenses data to that lab is not a provider, but the provider's obligations flow back into the license.

## Key dates

| Date | What happens |
| --- | --- |
| August 2, 2025 | GPAI obligations apply |
| July 2025 | Commission publishes the training content summary template |
| August 2, 2026 | AI Office enforcement powers, including fines, apply |

Source: [European Commission](https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai).

## The training content summary

Providers must publish a sufficiently detailed summary of the content used to train the model, following the Commission's template, including data sources ([European Commission](https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai)). Like California's [AB 2013](https://aidataforsale.com/ai-data-law/california-ab-2013), this means buyers need a disclosable description of licensed data.

## Copyright and opt-outs

Providers must put in place a policy to comply with EU copyright law, including identifying and respecting rights reservations under the text and data mining exception in Article 4 of the Digital Single Market Directive ([EUR-Lex](https://eur-lex.europa.eu/eli/dir/2019/790/oj)). Rights holders can reserve their works from text and data mining in a machine-readable way. Licensed data sidesteps that question because the license itself grants permission.

## What it means for US data sellers

- Expect EU-facing buyers to ask for a description of your data they can include in their summary.
- Expect warranties that you hold the rights you grant, and that the data does not include content you know was reserved from text and data mining.
- If the data includes personal information about people in the EU, the GDPR applies separately.

## What it means for AI teams

Keep a [data manifest](https://aidataforsale.com/learn/how-to-build-a-data-manifest) and license for every dataset. The same records support the EU summary, AB 2013 and buyer due diligence.

## Read next

- [California AB 2013](https://aidataforsale.com/ai-data-law/california-ab-2013)
- [AI data license agreement](https://aidataforsale.com/learn/ai-data-license-agreement)
- [Data provenance (glossary)](https://aidataforsale.com/glossary/data-provenance)

## Questions

### Does the EU AI Act ban training on copyrighted data?

No. It requires GPAI providers to have a copyright policy and respect text and data mining opt-outs, and to publish a training content summary. Licensing is one way to show permission.

### When can the EU fine GPAI providers?

The European Commission says the AI Office's enforcement powers, including fines, apply from August 2, 2026.

## Sources

- [European Commission: AI Act regulatory framework](https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai)
- [EUR-Lex: Directive (EU) 2019/790 on copyright in the Digital Single Market](https://eur-lex.europa.eu/eli/dir/2019/790/oj)