Which dated Commission documents govern when a GPAI training-content summary is due, updated and enforced, including for models placed on the market before 2 August 2025 and for fine-tuned models?
Per the Commission's Notice and its 19 November 2025 Guidelines, the GPAI training-content summary obligation applies from 2 August 2025; models already on the market before then must publish by 2 August 2027, stating and justifying any information gaps; AI Office enforcement starts 2 August 2026; summaries are updated at six-month intervals or sooner when additional training materially changes them; a downstream modifier that becomes a provider covers only the modification data; the summary is required for all of a provider's models, and models meeting the open-source conditions are not exempt.
Per the Commission's Notice and its 19 November 2025 Guidelines, the GPAI training-content summary obligation applies from 2 August 2025; models already on the market before then must publish by 2 August 2027, stating and justifying any information gaps; AI Office enforcement starts 2 August 2026; summaries are updated at six-month intervals or sooner when additional training materially changes them; a downstream modifier that becomes a provider covers only the modification data; the summary is required for all of a provider's models, and models meeting the open-source conditions are not exempt.
Curator qualifications: Documents read 2026-10-22; not legal advice; later amendments (e.g. simplification proposals) not checked. AI Act Article 53 text not re-read (producer pin).
Limitations: Documents read 2026-10-22; not legal advice; later amendments (e.g. simplification proposals) not checked.
Evidence status: statements located in the cited sources by a correlated desk review (Claude); not executed; not independently reviewed.
Structured fields
{
"citations": [
{
"url": "https://ec.europa.eu/newsroom/dae/redirection/document/118480",
"note": "Explanatory Notice and Template for the Public Summary of Training Content, paras 28-29 and section on application dates; Guidelines C(2025) 7719 final (Brussels, 19.11.2025), section 4 exceptions and modification paras"
},
{
"url": "https://ec.europa.eu/newsroom/dae/redirection/document/118340",
"note": "Explanatory Notice and Template for the Public Summary of Training Content, paras 28-29 and section on application dates; Guidelines C(2025) 7719 final (Brussels, 19.11.2025), section 4 exceptions and modification paras"
},
{
"url": "http://publications.europa.eu/resource/celex/32024R1689",
"note": "Explanatory Notice and Template for the Public Summary of Training Content, paras 28-29 and section on application dates; Guidelines C(2025) 7719 final (Brussels, 19.11.2025), section 4 exceptions and modification paras"
}
]
}Evidence claims
- [sourced_fact] Per the Commission's Notice and its 19 November 2025 Guidelines, the GPAI training-content summary obligation applies from 2 August 2025; models already on the market before then must publish by 2 August 2027, stating and justifying any information gaps; AI Office enforcement starts 2 August 2026; summaries are updated at six-month intervals or sooner when additional training materially changes them; a downstream modifier that becomes a provider covers only the modification data; the summary is required for all of a provider's models, and models meeting the open-source conditions are not exempt. · locator: Explanatory Notice and Template for the Public Summary of Training Content, paras 28-29 and section on application dates; Guidelines C(2025) 7719 final (Brussels, 19.11.2025), section 4 exceptions and modification paras source
Rights
| component | license | hosting | redistribution | modification | training | Evidence and notes |
|---|---|---|---|---|---|---|
| documentation | unknown | permitted | permitted | unknown | unknown | Applies to this original summary only, not to the cited sources. |