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ARTICLE · 02 OCTOBER 2025

Transparency Requirements Re Training Data And Compliance With Copyright Law Come Into Force In EU

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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Following the initial set of obligations that became applicable on 2 February 2025, a second wave of measures under the EU AI Act entered into force on 2 August 2025.

United KingdomIntellectual Property

Following the initial set of obligations that became applicable on 2 February 2025, a second wave of measures under the EU AI Act entered into force on 2 August 2025. These include:

  • Obligations for General Purpose AI models – As far as IP is concerned, providers of GPAI models are now required to comply with transparency and documentation requirements, including the publication of summaries of training data, implementation of risk mitigation measures, and ensuring compliance with EU copyright law.
  • The designation of notifying authorities and notified bodies
  • The framework for penalties and enforcement

Final version of the EU AI Act Code of Practice

The final version of the EU AI Act Code of Practice for General Purpose AI Models was released on 10 July 2025 and is structured around three key chapters: 1) Transparency, 2) Copyright and 3) Safety and Security.Although voluntary and not legally binding, the Code (applicable from 2 August 2025) is expected

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