The rules of the AI Act on GPAI and copyright are fully applicable.

From 2 August 2025, additional obligations of Regulation (EU) 2024/1689 (AI Act) are applicable, with an impact on the entire AI supply chain: model suppliers, users (deployers) and downstream suppliers (software houses, integrators, tech companies).

 

After the applicability – from 2 February – of the equally relevant rules on prohibited AI practices and AI literacy (e.g. of staff), the rules on transparency, which are fundamental for all AI systems that interact with people or generate digital content, even if not classified as high-risk (e.g.:  A virtual assistant integrated into an e-commerce site will have to make it clearly perceptible that the user is interacting with an automated system, unless it is obvious; a software house that generates advertising videos using AI will have to take technical measures - such as digital identifiers, invisible markers or traceability solutions in audio/video files - to make the artificial origin of the content produced or manipulated by AI recognizable).

 

In parallel, providers of general-purpose artificial intelligence (GPAI) models – such as GPT (model based on the ChatGPT system) – are required from tomorrow: (1) to draw up complete technical documentation, compliant with Annex XI of the AI Act; (2) to publish a summary of training data according to the template published this month by the EU Commission (3) to adopt a copyright policy, to demonstrate the lawfulness of the use of content in training and reduce the risk of output infringing third party rights (remember that GPAI providers already on the market before 2 August 2025 will be able to comply by 2 August 2027).

 

The EU Commission has adopted (1) a voluntary GPAI Code of Practice and (2) Technical Implementation Guidelines to assist providers in the application of documentary, transparency and security obligations.

 

The rules applicable from 2 August 2025 are not "compliance only". A restructuring of the relationships between (1) suppliers of models (2) downstream suppliers who adapt, resell or distribute them and (3) the companies that use them (deployers) is necessary. This is why supply, licence, etc. contracts will have to clearly reflect - by adapting the relevant clauses in the light of the AI Act - the obligations of technical documentation and disclosure; instructions for compliant use; the profiles of responsibility; copyright management policies; the management of updates; the correct allocation of responsibilities along the supply chain, etc.

 

The deadline of August 2 is therefore not at all symbolic: it represents a fundamental operational step for those who work with or use artificial intelligence.