EU General-Purpose AI Model Training Data Public Summary Template

Applies To

Overview

The European Commission adopted this template on 24 July 2025. Article 53(1)(d) of the EU AI Act requires every provider of a general-purpose AI model to publish a detailed summary of its training content. The summary must follow this template. The Commission describes it as mandatory, unlike the voluntary Code of Practice. The duty has applied since 2 August 2025. Models placed on the EU market before that date have until 2 August 2027. The template applies to all providers, including open-source releases and companies that substantially modify a model, wherever they are based. There is one template for every model; models with systemic risk carry other duties, not a different summary. The Commission can fine providers of general-purpose AI models up to EUR 15 million or 3% of worldwide annual turnover, with that power applying from 2 August 2026.

Key Requirements

• •Every general-purpose AI model provider must publish a training content summary using this template (Article 53(1)(d)).
• •The duty has applied since 2 August 2025; models already on the market before then have until 2 August 2027.
• •The summary covers the main data sources and types and how the data was collected and processed.
• •Summaries must be publicly available.
• •Models with systemic risk use the same template; their extra duties are evaluations, incident reporting, risk mitigation, and cybersecurity.
• •Fines can reach EUR 15 million or 3% of worldwide annual turnover, whichever is higher.

What Your Organization Must Do

• →Identify every general-purpose AI model your organisation provides or substantially modifies for the EU market.
• →Publish a training content summary using the Commission template, since Article 53(1)(d) requires it.
• →Record main data sources, data types, and how data was collected and processed.
• →Diarise 2 August 2027 for models placed on the EU market before 2 August 2025.
• →Note that fines of up to EUR 15 million or 3% of worldwide turnover apply from 2 August 2026.
• →Monitor Commission updates to the template and set an internal refresh cycle for published summaries.

Playbook Guidance

Step-by-step implementation guidance for compliance teams.

Frequently Asked Questions

Is the GPAI training data summary template legally binding or just a recommendation?

Using it is legally required. Article 53(1)(d) says the summary must follow a template provided by the AI Office, and the Commission calls it mandatory. Breaches can lead to fines of up to EUR 15 million or 3% of turnover.

What information must be included in a GPAI training data summary under this template?

At minimum, providers must disclose the main data sources, data types, and any filtering or selection criteria applied during training. The summary must be publicly accessible without restriction, enabling third parties to assess copyright, privacy, and bias considerations.

Does the GPAI training data summary requirement apply to AI model providers based outside the EU?

Yes. The requirement applies to all providers placing general-purpose AI models on the EU market, regardless of where the provider is established. Non-EU companies must complete and publish the template before or at the point of EU market placement.

When does the GPAI training data summary template take effect and what is the compliance deadline?

The duty has applied since 2 August 2025 for new models. Models already on the EU market before that date have until 2 August 2027 to publish a summary.

Do providers of systemic-risk GPAI models have additional disclosure obligations beyond this template?

Not for the training content summary, because all providers use the same template. Models with systemic risk carry other duties: notifying the AI Office, model evaluations, risk mitigation, serious incident reporting, and cybersecurity.

What happens if the European Commission revises the GPAI training data summary template after initial publication?

The Commission may revise the template as enforcement practice and technical understanding mature. Providers should monitor for updates and plan an internal update cycle for already-published summaries, since continued compliance with the underlying EU AI Act obligation depends on using the current template version.