The European Commission has opened a consultation to support the implementation of the AI Act’s obligations for providers of general-purpose AI (GPAI) models to identify and comply with rights reservations expressed by copyright holders. The consultation runs from 1 December 2025 to 9 January 2026.

The Copyright section of the GPAI Code of Practice, approved by the Commission, provides a framework for providers to meet their obligations under EU copyright rules, including the use of machine-readable protocols to indicate rights reservations, respecting standards such as robots.txt and its IETF updates.

The consultation invites rightsholders, AI providers, civil society, standardisation bodies, and other stakeholders to provide feedback on the technical feasibility and adoption of Text and Data Mining (TDM) opt-out solutions, as identified in the EUIPO study on generative AI and copyright. Stakeholders can also express interest in follow-up workshops to discuss protocols that GPAI Code signatories and other providers must respect.

An online information session will take place on 9 December 2025 to present the consultation process and the technical opt-out solutions. Based on stakeholder input, the Commission will publish a list of generally-agreed, machine-readable opt-out solutions, which will be reviewed at least every two years in line with updates to the Code of Practice.

This initiative aims to create a practical and widely adopted framework for respecting copyright in the development and deployment of AI models, while facilitating dialogue between rights holders and AI providers.