Does General-Purpose AI Code of Practice (GPAI CoP) require Data Governance?

European Union • enforcing

Yes — 1 provision

Requirements at a glance

This regulation imposes 5 specific requirements for Data Governance across 1 provision:

Training Data and Copyright Governance (Article 53) #

Obligation:
Data Governance
enforcing
Effective:
Aug 2, 2025
Risk tier:
all
Scope:
providers
high-impactcross-domain
All GPAI providers must implement copyright-compliant training data policies — including robots.txt compliance, mechanisms to prevent infringing outputs, and public training data disclosure. This directly affects every foundation model provider operating in or serving the EU, making EU copyright law a de facto data governance standard for global AI training pipelines.

Requirements

RequirementDetails
Copyright compliance policyImplement and maintain a policy for compliance with EU copyright law throughout the training data pipeline
Robots.txt complianceHonor robots.txt opt-out protocols when crawling data for training
Infringing output preventionEstablish mechanisms to prevent generation of copyright-infringing outputs
Complaint mechanismCreate a complaint mechanism for rights holders regarding copyright infringements
Training data disclosurePublicly disclose a summary of training data used, including data sources and characteristics

Penalties

ViolationFine
AI Act Article 53 infringementUp to €15 million or 3% of worldwide annual turnover (whichever is higher)
View full regulation View obligation Obligation matrix