Read the full pillar: EU AI Act Article 53 explainer →
What the regulation requires
1. Providers of general-purpose AI models shall: (a) draw up and keep up-to-date the technical documentation of the model, including its training and testing process and the results of its evaluation, which shall contain, at a minimum, the information set out in Annex XI for the purpose of providing it, upon request, to the AI Office and the national competent authorities; […] (c) put in place a policy to comply with Union law on copyright and related rights, and in particular to identify and comply with, including through state-of-the-art technologies, a reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790; (d) draw up and make publicly available a sufficiently detailed summary about the content used for training of the general-purpose AI model, according to a template provided by the AI Office. [Note: 53(1)(b) on information packs to downstream providers integrating the model (Annex XII content) is omitted here for brevity. Downstream-provider documentation is the scope of TransparencyDeck (in development) — License Compliance Checker addresses 53(1)(a) technical documentation, 53(1)(c) copyright policy, and 53(1)(d) training-data summary.]
What you face if you don't comply
Article 53 has been applicable since 2 August 2025 (Art. 113(b)) — GPAI providers placing models on the EU market today owe technical documentation (53(1)(a)), downstream-provider information packs (53(1)(b), Annex XII), a copyright-compliance policy aligned with Directive (EU) 2019/790 Article 4(3) (53(1)(c)), and a public training-data summary on the AI Office template (53(1)(d)). Commission-imposed fines under Article 101 are excluded from the 2025-08-02 date by Art. 113(b) and apply from 2 August 2026 — up to €15M or 3% of global annual turnover, whichever is higher. Transitional regime per Art. 111(3): GPAI models placed on the EU market before 2 August 2025 have until 2 August 2027 to comply. The operational reality is that the copyright-policy and training-data-summary obligations require auditable evidence at the dataset level, not assertions in a model card.
How License Compliance Checker addresses this
- ¶ 53(1)(a)Generates per-model SBOM-style training-data manifests fit for inclusion in the Annex XI technical documentation pack
- ¶ 53(1)(c)Detects rights-reservation signals (TDM opt-outs, robots.txt, ai.txt) across training corpora to evidence the Art. 4(3) Directive 2019/790 policy
- ¶ 53(1)(c)Flags incompatible-licence content (NC, ND, viral copyleft) before it enters a training run, with provenance trail
- ¶ 53(1)(d)Produces the public training-content summary in the AI Office template format, regenerated on each dataset revision
Source: eur-lex.europa.eu/…/CELEX:32024R1689 · Retrieved