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, at the latest when the model is placed on the market; the open-source exemption in Article 53(2) does not cover this summary. The Commission's mandatory template was issued on 24 July 2025 (C(2025) 5235 final) and formally adopted as a Commission Communication on 5 December 2025 (C(2025) 8311 final).

2 August 2026 — enforcement powers apply

The Commission's supervision and enforcement powers over GPAI providers, exercised through the AI Office, apply (Articles 88–94). Fines for non-compliance with GPAI obligations, imposed by the Commission, can reach €15 million or 3% of total worldwide annual turnover in the preceding financial year, whichever is higher (Article 101).

2 August 2027 — legacy-model 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 (Article 111(3)). The Explanatory Notice allows such a provider that cannot, despite best efforts, provide parts of the required information to state and justify the gaps in its summary.

Six-month intervals — updates after further training

The Regulation sets no fixed update cadence. The Commission's Explanatory Notice directs a provider that further trains a model already on the market on additional data requiring a change to the summary to update it at six-month intervals, or sooner if that data requires a materially significant change to the summary's content — whichever comes first — recording the date of each update. The GPAI Ledger's daily capture makes those updates — and any silent edits — visible as a version chain.

Unchanged by the Digital Omnibus

The Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026) postponed several high-risk and transparency deadlines but left the obligations of general-purpose AI model providers in Articles 51–55 — and every date on this page — unchanged.

Read the Regulation on EUR-Lex · Regulation (EU) 2026/1744 (Digital Omnibus on AI).