Operational guidance, not legal advice. This page distills named public sources (regulator guidance and industry practice). It is not a legal determination, not a notification decision, and not a substitute for your counsel, insurer, or a retained DFIR firm. Verify applicability and current deadlines for your facts and jurisdiction.
What copyright policy does the EU AI Act require?
Updated
Article 53(1)(c) of Regulation (EU) 2024/1689 is a GPAI-provider policy to comply with Union copyright law, including DSM Directive Article 4(3) TDM reservations. Not legal advice. This page does not determine that YOU have to adopt a copyright policy.
AI Act copyright policy, last verified 9 September 2026 against Articles 53(1)(c), 53(2), 53(4), 111(3) and 113 of Regulation (EU) 2024/1689 (OJ L 2024/1689, 12.7.2024) and Recitals 105, 106 and 108. Directive (EU) 2019/790 (DSM) Articles 3 and 4 are the underlying TDM exception and reservation. The GPAI Code of Practice copyright chapter is Commission / AI Office material — guidance, not the regulation. This page is not legal advice, not a filing, not a determination that YOU have to adopt a copyright policy, and does not start a clock.
This is Article 53(1)(c) versus DSM copyright law, not YOUR policy
Audience: a GPAI-model provider, engineering lead, or counsel walking Regulation (EU) 2024/1689 on the copyright-policy duty. This page is not legal advice. It does not start a clock. Reading it does not start a clock. Mapping a row is not a determination that the Act applies, that YOU are a GPAI provider, or that YOU have to adopt a copyright policy. This page does not file with the AI Office. This product does not write YOUR policy.
The AI Act is Regulation (EU) 2024/1689 of 13 June 2024, OJ L 2024/1689, 12.7.2024. ELI: http://data.europa.eu/eli/reg/2024/1689/oj. Article 53(1)(c) is a GPAI-provider policy to comply with Union law on copyright and related rights, in particular to identify and comply with a reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790. Directive (EU) 2019/790 is a different instrument: the Digital Single Market copyright directive. The GPAI Code of Practice copyright chapter is guidance, not the regulation. The EU AI Act overview on this site is the pillar page. The GPAI-requirements guide on this site is the Article 53 baseline page. The training-data-transparency guide on this site is the Article 53(1)(d) page. Last verified 9 September 2026. Not legal advice.
- Statute versus underlying copyright law versus guidance: Article 53(1)(c) of 2024/1689 is a legal requirement only if it applies. Recitals 105, 106 and 108 are recitals, not operative articles. Directive (EU) 2019/790 Articles 3 and 4 are the underlying TDM exception and reservation. The GPAI Code of Practice copyright chapter is Commission / AI Office material — guidance, not the regulation. This page quotes which kind of text it is relying on.
- The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-requirements guide on this site is the Article 53 baseline page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The AI-incident-reporting guide on this site is the Articles 3(49), 55 and 73 page. A dedicated AI-cybersecurity-requirements guide is not on this site yet. Naming it is not a link.
- This page does not invent a 2 August 2026 start date for the GPAI copyright-policy duty. Article 53 sits in Chapter V. Article 113(b) applies Chapter V from 2 August 2025, with the exception of Article 101. Article 53(1)(c) therefore applies from 2 August 2025 under Article 113(b), except Article 101. It did not start on 2 August 2026. Article 113(c) of 2024/1689 keeps Article 6(1) and the corresponding obligations — Annex I product-embedded high-risk — on 2 August 2027, not 2 August 2026. This page does not invent a 2 August 2026 date for Annex I.
Article 53(1)(c) is not DSM Article 4, and is not Article 53(1)(d)
Do not conflate them. Article 53(1)(c) is an AI Act duty to put in place a policy to comply with Union copyright law, including identifying and complying with DSM Article 4(3) reservations. Directive (EU) 2019/790 Articles 3 and 4 are the underlying TDM exception and the rightholder reservation. Article 53(1)(d) is a different GPAI point: a public training-content summary. Recital 108 treats the copyright-policy duty and the public summary as two obligations. A policy is not a summary. A TDM reservation is not an AI Act policy. Mapping a row is not a finding that any of those texts bind YOU. Last verified 9 September 2026. Not legal advice.
| Track | What the cited text is | Kind of text | Last verified |
|---|---|---|---|
| Article 53(1)(c) — GPAI copyright policy | Providers of general-purpose AI models shall put in place a policy to comply with Union law on copyright and related rights, and in particular to identify and comply with, including through state-of-the-art technologies, a reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790. Legal requirement if YOU are a GPAI provider. In force 2 August 2025 via Article 113(b). This page does not determine that YOU are a GPAI provider and does not determine that YOU have to adopt a copyright policy. | Article 53(1)(c) of 2024/1689. Legal requirement, only if it applies. Distinct from DSM Articles 3–4 and from Article 53(1)(d). This product does not write YOUR policy. | 9 September 2026 |
| Directive (EU) 2019/790 Articles 3–4 — underlying TDM exception and reservation | Article 3 is a TDM exception for research organisations and cultural heritage institutions for scientific research. Article 4 is a TDM exception or limitation for reproductions and extractions of lawfully accessible works, on condition that the use has not been expressly reserved by rightholders in an appropriate manner, such as machine-readable means for content made publicly available online. Article 4(4) says Article 4 shall not affect Article 3. Distinct from the AI Act policy duty. | Directive (EU) 2019/790. Underlying copyright law. Not Article 53(1)(c). This page does not apply DSM law to YOUR corpus. | 9 September 2026 |
| Article 53(1)(d) — public training-content summary, a different GPAI point | Article 53(1)(d) is a public summary of the content used to train a general-purpose AI model, according to a template provided by the AI Office. Recital 108 treats the copyright-policy duty and the public summary as two obligations. The training-data-transparency guide on this site is the Article 53(1)(d) page. | Article 53(1)(d) of 2024/1689. Legal requirement, only if it applies. Distinct from Article 53(1)(c). This page does not publish YOUR summary. | 9 September 2026 |
| GPAI Code of Practice copyright chapter | The GPAI Code of Practice has a copyright chapter. Commission materials describe it as practical solutions for the Article 53(1)(c) policy duty. Adherence is voluntary. Article 53(4) permits relying on an Article 56 code to demonstrate compliance with Article 53(1) until a harmonised standard is published. That permission does not replace Article 53(1)(c). | Commission / AI Office material. Guidance, not the regulation. Distinct from Article 53(1)(c) and from DSM Articles 3–4. | 9 September 2026 |
What original Article 53(1)(c) actually says
Last verified 9 September 2026 against Article 53 of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). These are legal requirements of the original regulation, only if they apply. This page does not apply them to YOU. Not legal advice.
| Point | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Article 53(1)(c) | Authentic Article 53(1)(c): Providers of general-purpose AI models shall put in place a policy to comply with Union law on copyright and related rights, and in particular to identify and comply with, including through state-of-the-art technologies, a reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790. | Article 53(1)(c) of 2024/1689. Legal requirement, only if it applies. This page does not write YOUR policy and does not scan YOUR corpus. | 9 September 2026 |
| Recital 105 — TDM and the rightholder reservation | Recital 105: Directive (EU) 2019/790 introduced exceptions and limitations allowing reproductions and extractions of works or other subject matter, for the purpose of text and data mining, under certain conditions. Under these rules, rightsholders may choose to reserve their rights over their works or other subject matter to prevent text and data mining, unless this is done for the purposes of scientific research. Where the rights to opt out has been expressly reserved in an appropriate manner, providers of general-purpose AI models need to obtain an authorisation from rightsholders if they want to carry out text and data mining over such works. | Recital 105 of 2024/1689. A recital, not an operative article. It does not rewrite Article 53(1)(c) or DSM Article 4(3). This page does not treat a recital as the article. | 9 September 2026 |
| Recital 106 — the policy, including training outside the Union | Recital 106: providers of general-purpose AI models should put in place a policy to comply with Union law on copyright and related rights, in particular to identify and comply with the reservation of rights expressed by rightsholders pursuant to Article 4(3) of Directive (EU) 2019/790. Any provider placing a general-purpose AI model on the Union market should comply with this obligation, regardless of the jurisdiction in which the copyright-relevant acts underpinning the training of those general-purpose AI models take place. | Recital 106 of 2024/1689. A recital, not an operative article. This page does not run the non-EU training test. Counsel reads Article 53(1)(c) and, if useful, the recital. | 9 September 2026 |
| Recital 108 — policy versus copyright enforcement | Recital 108: with regard to the obligations imposed on providers of general-purpose AI models to put in place a policy to comply with Union copyright law and make publicly available a summary of the content used for the training, the AI Office should monitor whether the provider has fulfilled those obligations without verifying or proceeding to a work-by-work assessment of the training data in terms of copyright compliance. This Regulation does not affect the enforcement of copyright rules as provided for under Union law. | Recital 108 of 2024/1689. A recital, not an operative article. The AI Act policy duty is not a substitute for underlying copyright enforcement. Distinct from Article 53(1)(d). | 9 September 2026 |
| Article 53(2) — exception for points (a) and (b) only | The obligations set out in paragraph 1, points (a) and (b), shall not apply to providers of AI models that are released under an open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available. This exception shall not apply to general-purpose AI models with systemic risks. Points (c) and (d) — the copyright policy and the public training-content summary — are not in that exception. This page does not qualify YOUR licence. | Article 53(2) of 2024/1689. Legal requirement of the exception, only if it applies. Counsel reads the authentic paragraph. | 9 September 2026 |
| Article 53(4) — codes of practice do not replace paragraph 1 | Providers of general-purpose AI models may rely on codes of practice within the meaning of Article 56 to demonstrate compliance with the obligations set out in paragraph 1 of this Article, until a harmonised standard is published. Providers who do not adhere to an approved code of practice or do not comply with a European harmonised standard shall demonstrate alternative adequate means of compliance for assessment by the Commission. | Article 53(4) of 2024/1689. Legal requirement of the permission, only if it applies. Does not replace Article 53(1)(c). The GPAI Code of Practice is guidance, not the regulation. | 9 September 2026 |
| Article 111(3) — models already on the market before 2 August 2025 | Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027. That is a legal requirement of the original regulation, only if it applies. It is not Article 113(c). This page does not decide that YOUR model was placed on the market before 2 August 2025. | Article 111(3) of 2024/1689. Legal requirement, only if it applies. Distinct from Article 113(b) and from Article 113(c). | 9 September 2026 |
DSM Directive Articles 3 and 4 are the underlying TDM law
Last verified 9 September 2026 against Directive (EU) 2019/790 of 17 April 2019 (OJ L 130, 17.5.2019, p. 92), ELI: http://data.europa.eu/eli/dir/2019/790/oj. Article 53(1)(c) points at Article 4(3) of that directive. The AI Act does not rewrite DSM Articles 3–4. Putting a policy in place is not a finding that a DSM exception applied to YOUR training. Not legal advice.
| Point | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Article 3 — TDM for scientific research | Member States shall provide for an exception to specified reproduction and extraction rights for reproductions and extractions made by research organisations and cultural heritage institutions in order to carry out, for the purposes of scientific research, text and data mining of works or other subject matter to which they have lawful access. | Directive (EU) 2019/790 Article 3. Underlying copyright law. Distinct from Article 4. Recital 105 of 2024/1689 notes the scientific-research reservation is not available. This page does not qualify YOUR research. | 9 September 2026 |
| Article 4(1)–(2) — TDM exception or limitation | Member States shall provide for an exception or limitation to specified reproduction and extraction rights for reproductions and extractions of lawfully accessible works and other subject matter for the purposes of text and data mining. Reproductions and extractions made pursuant to paragraph 1 may be retained for as long as is necessary for the purposes of text and data mining. | Directive (EU) 2019/790 Article 4(1)–(2). Underlying copyright law. The exception applies only if Article 4(3) is met. This page does not decide that YOUR copies were lawful. | 9 September 2026 |
| Article 4(3) — the reservation Article 53(1)(c) names | Authentic Article 4(3): The exception or limitation provided for in paragraph 1 shall apply on condition that the use of works and other subject matter referred to in that paragraph has not been expressly reserved by their rightholders in an appropriate manner, such as machine-readable means in the case of content made publicly available online. | Directive (EU) 2019/790 Article 4(3). Underlying copyright law. The reservation the AI Act policy must identify and comply with. This product does not detect YOUR opt-outs. | 9 September 2026 |
| Article 4(4) — Article 4 does not affect Article 3 | This Article shall not affect the application of Article 3 of this Directive. | Directive (EU) 2019/790 Article 4(4). Underlying copyright law. Do not treat an Article 4 reservation as blocking Article 3 scientific-research TDM. | 9 September 2026 |
Does Recital 106 decide non-EU training? This page does not run that test
Last verified 9 September 2026 against Recital 106 of Regulation (EU) 2024/1689. Recital 106 says any provider placing a general-purpose AI model on the Union market should comply with the copyright-policy obligation, regardless of the jurisdiction in which the copyright-relevant acts underpinning the training of those models take place. That is a recital, not an operative article. Article 53(1)(c) is the operative duty, only if it applies. This page does not run the non-EU training test. It does not determine that training outside the Union is in or out. Counsel reads Article 53(1)(c), Article 2 territorial scope, and, if useful, Recital 106 as a recital. Mapping a row is not that determination. Not legal advice.
Recital 108 adds that the AI Office should monitor whether the provider has put the policy in place and published the training-content summary, without a work-by-work copyright assessment of the training data, and that the AI Act does not affect enforcement of copyright rules under Union law. The AI Act duty is to put a policy in place. Underlying copyright and DSM law remain a different enforcement track. This page does not merge them. Last verified 9 September 2026. Not legal advice.
The GPAI Code of Practice copyright chapter is guidance, not the regulation
Last verified 9 September 2026 against the Commission page The General-Purpose AI Code of Practice at https://digital-strategy.ec.europa.eu/en/policies/contents-code-gpai (published 10 July 2025). That page describes three chapters: Transparency, Copyright, and Safety and Security. The copyright chapter, the Commission says, offers providers practical solutions to meet the AI Act obligation to put in place a policy to comply with EU copyright law. Those materials are Commission / AI Office guidance, not the regulation. Adherence is voluntary. Article 53(4) permits relying on an Article 56 code to demonstrate compliance with Article 53(1) until a harmonised standard is published. That permission does not replace Article 53(1)(c).
Commission follow-up materials describe Code copyright-chapter measures such as identifying and complying with rights reservations when crawling, mitigating copyright-infringing outputs, and designating contact points for rightholder complaints. Those measure numbers and labels are Code of Practice / Commission material — guidance, not the regulation. Filling a Code measure is not a determination that Article 53(1)(c) is met. This product does not implement those measures for you and does not write YOUR policy. Last verified 9 September 2026. Not legal advice.
Article 113: GPAI copyright policy is 2 August 2025, not 2 August 2026
Last verified 9 September 2026 against Article 113 of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Article 53 sits in Chapter V. Article 113(b): Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101. The GPAI copyright-policy duty in Article 53(1)(c) therefore applies from 2 August 2025 under Article 113(b), except Article 101. It did not start on 2 August 2026. This page does not invent a 2 August 2026 start date for GPAI.
Article 113(c) keeps Article 6(1) and the corresponding obligations — Annex I product-embedded high-risk — on 2 August 2027, not 2 August 2026. This page does not invent a 2 August 2026 date for Annex I. Article 111(3) gives providers of GPAI models placed on the market before 2 August 2025 until 2 August 2027 to take the necessary steps. That is not Article 113(c). Regulation (EU) 2026/1744 is an amending regulation. Counsel reads the authentic operative article of any amendment. This page does not apply 2026/1744 to YOU. It does not rewrite Article 113(b) for Chapter V in the original regulation. Not legal advice.
Legal requirement versus guidance versus ShipReady recommendation
The table below labels each text. Do not treat the Code of Practice as Article 53(1)(c), do not treat a recital as the article, and do not treat a product surface as a determination. Last verified 9 September 2026. Not legal advice.
| Text | What it is | What this page does not do |
|---|---|---|
| Regulation (EU) 2024/1689 Article 53(1)(c) | Legal requirement — GPAI-provider policy to comply with Union copyright law, including DSM Article 4(3) reservations, only if YOU are a GPAI provider. In force 2 August 2025 under Article 113(b), except Article 101. Distinct from Article 53(1)(d). | Does not determine that YOU have to adopt a copyright policy. Does not invent a 2 August 2026 start date for GPAI. This product does not write YOUR policy. |
| Directive (EU) 2019/790 Articles 3–4 | Underlying copyright law — TDM exception for scientific research (Article 3) and TDM exception or limitation with rightholder reservation (Article 4, including Article 4(3)). Distinct from the AI Act policy duty. | Does not apply DSM law to YOUR corpus. Does not detect YOUR opt-outs. Does not treat a DSM reservation as the AI Act policy. |
| Recitals 105, 106 and 108 of 2024/1689 | Recitals, not operative articles. Recital 106 discusses placing a model on the Union market regardless of the training jurisdiction. Recital 108 distinguishes AI Office monitoring of the policy from work-by-work copyright enforcement. | Does not run the non-EU training test. Does not treat a recital as rewriting Article 53(1)(c). |
| GPAI Code of Practice copyright chapter | Commission / AI Office material. Guidance, not the regulation. The Code is a voluntary tool. Article 53(4) permits relying on an Article 56 code to demonstrate compliance until a harmonised standard is published. | Does not treat the Code as replacing Article 53(1)(c). |
| This product's AI-governance surface | ShipReady recommendation: an inventory and posture of facts the organisation recorded. Not a copyright policy. Not legal advice. | Does not write YOUR copyright policy. Does not scan YOUR training corpus. Does not determine that YOU have to adopt a copyright policy. A named human still owns the assessment. |
What to do now
As of last verification on 9 September 2026, Article 53 GPAI duties, including the copyright-policy duty, have applied since 2 August 2025 under Article 113(b), except Article 101. Article 111(3) gives providers of models placed on the market before 2 August 2025 until 2 August 2027 to take the necessary steps. The list below is operational preparation. It is not a determination that YOU have to adopt a copyright policy. Walk it with counsel.
- Ask counsel whether YOU are a provider of a general-purpose AI model under Articles 3(3) and 3(63). This page does not run that test. Marking eu_ai_act in an obligation map is not that determination and is not a policy-adoption determination.
- If counsel finds YOU are a GPAI provider, walk Article 53(1)(c) as written: a policy to comply with Union copyright law, including identifying and complying with DSM Article 4(3) reservations, including through state-of-the-art technologies. Do not treat the Code of Practice copyright chapter as replacing that article. Do not date the duty from 2 August 2026. Article 113(b) is 2 August 2025. This product does not write YOUR policy.
- Keep DSM Articles 3–4 separate. Article 3 is scientific-research TDM. Article 4 is the reservable TDM exception. Article 53(1)(c) points at Article 4(3). Recital 106 does not run YOUR non-EU training test. This page does not run it either.
- The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-requirements guide on this site is the Article 53 baseline page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The AI-incident-reporting guide on this site is the Articles 3(49), 55 and 73 page. A dedicated AI-cybersecurity-requirements guide is not on this site yet. Naming it is not a link.
Checklist
This is a question list, not a determination that YOU have to adopt a copyright policy, and not a filing. Walk it with counsel. The GPAI-requirements guide on this site is the Article 53 baseline page. The training-data-transparency guide on this site is the Article 53(1)(d) page.
- Does the Act apply to YOU at all? Articles 2 and 3. This page does not run that test.
- Are YOU a provider of a general-purpose AI model? Articles 3(3) and 3(63). Article 53(1)(c) is a legal requirement only if that applies. This page does not determine that YOU are a GPAI provider and does not determine that YOU have to adopt a copyright policy.
- Does Article 53(2) as written actually except YOUR copyright policy? Points (c) and (d) are not in that exception. This page does not qualify YOUR licence.
- Is DSM Article 4 the same as the AI Act policy? No. Article 53(1)(c) is a policy to comply with Union copyright law, including identifying and complying with Article 4(3) reservations. DSM Articles 3–4 remain underlying copyright law.
- Does this page decide whether non-EU training is covered? No. Recital 106 is a recital. This page does not run that test.
- Does the GPAI Code of Practice replace Article 53(1)(c)? No. The Code is voluntary guidance. Article 53(4) is a permission, not a substitute.
- Did the GPAI copyright-policy duty start 2 August 2026? No. Article 113(b) is 2 August 2025, not 2026.
- Does this page write our policy, or does the product write it? No. This product does not write YOUR copyright policy and does not scan YOUR corpus.
- Document the assessment, including a not-required decision. This page does not keep YOUR file.
Where this shows up in ShipReady Metrics
The bundled framework key eu_ai_act is customer-visible. Its version label is Regulation (EU) 2024/1689 high-risk obligations (starter subset). It is not in INTERNAL_TESTER_ONLY_FRAMEWORKS. The control-set is a starter subset, illustrative, to be tailored by a compliance owner; not legal advice; not a conformity determination; not CE marking. Readiness is not compliance and not an EU-database registration.
If you already have a session: signed-in app → Compliance → AI governance holds the AI inventory and AI-governance posture. That inventory can record facts the organisation declared. Recording a posture is not putting in place an Article 53(1)(c) policy, is not a DSM Article 4(3) opt-out scan, and is not a determination that YOU have to adopt a copyright policy. Marking in-scope is not a policy-adoption determination and not auto-filing. A named human still owns the assessment.
This product does not write YOUR copyright policy, does not scan YOUR training corpus, does not identify TDM reservations for you, does not publish a training-content summary, does not file with the AI Office, and does not issue certifications. The obligation map lists frameworks the organisation has marked in-scope, including eu_ai_act if that mark is set. Marking eu_ai_act in-scope is not a determination that you have to adopt a copyright policy.
This page does not document a public demo URL. There is no public EU AI Act demo path. This product does not start a clock.
Primary sources (last verified 9 September 2026)
Every regulatory or guidance claim on this page is taken from one of these. If a later revision of a source changes the rule, the date above is how you can see we have not re-checked yet.
Regulation (EU) 2024/1689 of 13 June 2024 (Artificial Intelligence Act), Articles 53(1)(c), 53(2), 53(4), 111(3) and 113 and Recitals 105, 106 and 108, is a legal requirement only if it applies. Entry into force 1 August 2024. Article 113(a) 2 February 2025; Article 113(b) 2 August 2025; general application 2 August 2026; Article 113(c) Article 6(1) from 2 August 2027. Directive (EU) 2019/790 of 17 April 2019 (DSM), Articles 3 and 4, is the underlying TDM exception and reservation. Commission AI Act pages and the GPAI Code of Practice, including its copyright chapter, are Commission / AI Office materials — guidance, not the regulation. The GPAI Code of Practice is voluntary and does not replace Article 53(1)(c). Regulation (EU) 2026/1744 is an amending regulation. These are not a complete world list. Not legal advice.
The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-requirements guide on this site is the Article 53 baseline page. The GPAI-systemic-risk guide on this site is the Article 51–55 page. The provider-vs-deployer guide on this site is the Articles 3, 16, 25 and 26 page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The EU AI Act framework guide on this site is the education page under frameworks. The AI-incident-reporting guide on this site is the Articles 3(49), 55 and 73 page. A dedicated AI-cybersecurity-requirements guide is not on this site yet. Naming it is not a link.
Frequently asked questions
Is this legal advice?
No. It is a dated map of the GPAI copyright-policy duty distilled from Regulation (EU) 2024/1689 Article 53(1)(c), with Directive (EU) 2019/790 Articles 3–4 labelled as underlying copyright law and the GPAI Code of Practice copyright chapter labelled as guidance, not the regulation. Whether those articles apply to YOU, and whether YOU have to adopt a copyright policy, is a legal question for counsel on your facts. This page does not start a clock and does not file with the AI Office.
Does this apply to non-EU training?
This page does not run that test. Recital 106 of Regulation (EU) 2024/1689 discusses providers placing a general-purpose AI model on the Union market regardless of the jurisdiction in which the copyright-relevant training acts take place. That is a recital, not an operative article. Article 53(1)(c) is the operative duty, only if it applies. Counsel reads Article 53(1)(c), Article 2, and, if useful, Recital 106. Mapping a row is not that determination. Last verified 9 September 2026.
Does the GPAI Code of Practice replace Article 53(1)(c)?
No. The GPAI Code of Practice is a voluntary tool. Its copyright chapter is Commission / AI Office material — guidance, not the regulation. Article 53(4) permits relying on an Article 56 code to demonstrate compliance with Article 53(1) until a harmonised standard is published. That permission does not replace Article 53(1)(c). Last verified 9 September 2026.
Did the GPAI copyright-policy duty start on 2 August 2026?
No. Article 113(b) of Regulation (EU) 2024/1689 applies Chapter V from 2 August 2025, with the exception of Article 101. Chapter V includes Article 53. That is not 2 August 2026. This page does not invent a 2 August 2026 start date for GPAI. Article 111(3) is 2 August 2027 for models already on the market before 2 August 2025. Article 113(c) Annex I is 2 August 2027, not 2026. Last verified 9 September 2026.
Does this page write our copyright policy?
No. This page does not write a copyright policy, does not scan YOUR training corpus, and does not identify DSM Article 4(3) reservations for you. Mapping a row is not a finding that the Act applies, that YOU are a GPAI provider, or that Article 53(1)(c) binds YOU. Counsel applies Article 53(1)(c) to YOUR facts. Last verified 9 September 2026.
Does marking eu_ai_act in-scope mean we have to adopt a copyright policy?
No. Marking the bundled framework key eu_ai_act in-scope on the obligation map is not a determination that you have to adopt a copyright policy, is not a finding that Article 53(1)(c) applies, and is not auto-filing. Counsel applies that article to YOUR facts. A named human still owns the assessment.
Does ShipReady write our copyright policy?
No. This product does not write YOUR copyright policy and does not scan YOUR training corpus. Signed-in app → Compliance → AI governance can record facts the organisation declared. That record is not an Article 53(1)(c) policy. This product does not file with the AI Office. A named human still owns the assessment.
Published by ShipReady Metrics, an evidence-based technology and compliance intelligence platform. This guide is educational and vendor-neutral.