When training-data summaries are due
Article 53(1)(d), Regulation (EU) 2024/1689 — the timeline
2 August 2025 — the obligation starts
Providers placing a general-purpose AI model on the EU market from this date must publish the training-content summary. The Commission's mandatory template was published in July 2025 (C(2025) 5235, later reissued in formal adoption as C(2025) 8311 final).
2 August 2026 — enforcement powers apply
The AI Office's enforcement powers for GPAI obligations apply. Fines for non-compliance with GPAI obligations can reach €15 million or 3% of worldwide annual turnover, whichever is higher (Article 101).
2 August 2027 — legacy models deadline
Providers of models placed on the market before 2 August 2025 must have brought them into compliance — including the public training-content summary — by this date.
Every 6 months — updates
Summaries must be kept up to date while the model is on the market; the Commission's Explanatory Notice directs updates when further training materially changes the disclosure, at a cadence of at least every six months where such updates are required. The GPAI Ledger's daily capture makes those updates — and any silent edits — visible as a version chain.