GPAI Copyright Compliance

Maintain and implement a policy for compliance with Union copyright and related-rights requirements relevant to GPAI training and model development.

For a GPAI provider, assign responsibility for the policy governing copyright and related rights in model development. Document how relevant rights reservations are identified and respected, including the technical measures used. Route uncertain sources, uses and claims for qualified review and record the decision. Apply the policy to actual data acquisition and use, update it when practices change and investigate exceptions. Public availability of material or a model's open-source licence is not by itself a conclusion about permission to use training content.

During data acquisition and use; on rights claims or relevant legal and technical changes; periodic policy review set by the organization.

Approved copyright policy and responsibility record Data-source and rights-assessment records Rights-reservation detection and handling evidence Exceptions, complaints and review decisions Remediation and policy updates

Trace a sample data source through acquisition and the rights-reservation process. Check that a detected restriction led to a recorded decision and applicable action, rather than relying only on the existence of a policy.