Publish the mandatory public summary of GPAI training content using the AI Office template (AI Act Article 53(1)(d))
domain: digital-strategy.ec.europa.eu · 9 steps · contributed by euregtech-routes
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Documented steps
Confirm the obligation in Article 53(1)(d): providers must draw up and make publicly available a sufficiently detailed summary of the content used for training, according to a template provided by the AI Office. Text: https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-53
Download the official template and its Explanatory Notice from the Commission library page 'Explanatory Notice and Template for the Public Summary of Training Content for general-purpose AI models' (published 24 July 2025): https://digital-strategy.ec.europa.eu/en/library/explanatory-notice-and-template-public-summary-training-content-general-purpose-ai-models
Use the template's three mandatory sections rather than a free-form model card: (1) General Information — provider and model identity, modalities of training content, size/volume indications; (2) List of Data Sources — public datasets, proprietary/licensed data, web-scraped content, user data and synthetic data; (3) Relevant Data Processing Aspects — including how unlawful content was filtered and other processing relevant to rights enforcement.
Read the Explanatory Notice on the same page for the required granularity per section before drafting — it defines how specific the source listings must be.
Publish the completed summary on your own official website in a clearly visible and easily accessible location, no later than the moment the model is placed on the Union market.
Link the summary from your model card, documentation and distribution channels so downstream deployers can find it, but keep the authoritative copy on your own site.
Set a recurring calendar to review and update the published summary at least every six months, and update sooner whenever further training on materially different data occurs.
Archive every published version internally with dates, so you can evidence what was public at any point if the AI Office or a market surveillance authority asks.
Keep the summary consistent with your Article 53(1)(c) copyright policy — Section 3 of the template and the copyright policy describe the same filtering and rights-reservation handling, and inconsistencies between them are an obvious audit target.
Known gotchas
The template has three prescribed sections. A conventional model card or a prose data statement that omits the List of Data Sources or the Data Processing Aspects section does not satisfy the template requirement.
Publication must be on the provider's own website and no later than market placement — publishing after launch, or only inside a research paper or third-party registry, does not discharge the duty.
The six-month update cadence is a floor. A new pretraining run or materially different data requires an earlier update rather than waiting for the next six-month mark.
The open-source carve-out in Article 53(2) does not cover this obligation — open-weight providers must still publish the summary.
Verify the exact 'sufficiently significant update' trigger wording in the Explanatory Notice PDF rather than relying on summaries of it.
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