Policy Brief: Transparency Template for GPAI Training Content

On July 24, 2025, the European Commission published the Template for the Public Summary of Training Data for General-Purpose AI (GPAI) Models, as required by Article 53(1)(d) of the AI Act (Regulation (EU) 2024/1689). Starting from August 2, 2025, all providers of GPAI models placed on the EU market — including open-source ones — must make publicly available a sufficiently detailed narrative summary of the data used for training.

Our new Policy Brief provides a concise yet in-depth analysis of this new transparency obligation, clarifying its regulatory purpose and practical implications, particularly in relation to copyright, data governance, and regulatory compliance strategies.

The document is aimed at developers, regulators, rights holders, and downstream stakeholders, offering insights into:

  • What information must be disclosed according to the new template;

  • How to handle sensitive content, such as data scraped from the web or protected by copyright;

  • Why transparency is now a tool for accountability, not just a formal requirement.

Download the PDF here: Policy Brief: Transparency Template for GPAI Training Content – Pollicino AI Advisory