Implement the AI Act Article 53(1)(c) copyright policy and honour machine-readable TDM rights reservations for GPAI training

Documented steps

1. Read Article 53(1)(c): providers must put in place a policy to comply with Union copyright law 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. Text: https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-53
2. Read Article 4 of Directive (EU) 2019/790 for the underlying text-and-data-mining exception and the opt-out mechanism, which requires reservations to be expressed in an appropriate manner such as machine-readable means for content made publicly available online: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019L0790
3. Write and adopt a documented copyright policy covering data sourcing and scraping practices, how machine-readable rights reservations are detected and honoured during collection and pre-processing, and how the policy is kept current.
4. Implement the detection technically in the crawler and ingestion pipeline, not only on paper — Article 53(1)(c) requires identification 'including through state-of-the-art technologies', so a policy document without pipeline enforcement does not satisfy it.
5. At minimum honour robots.txt-expressed reservations, and track the Commission's work on standardised machine-readable opt-out protocols. The Commission and EUIPO ran a consultation on protocols for reserving rights from text and data mining: https://digital-strategy.ec.europa.eu/en/consultations/commission-launches-consultation-protocols-reserving-rights-text-and-data-mining-under-ai-act-and
6. When the Commission publishes its list of generally agreed machine-readable opt-out solutions, update the pipeline to recognise every listed protocol; treat robots.txt alone as a floor rather than a safe harbour.
7. Consider adhering to the Copyright chapter of the General-Purpose AI Code of Practice as a voluntary demonstration route: https://digital-strategy.ec.europa.eu/en/policies/contents-code-gpai
8. Keep the copyright policy consistent with Section 3 of your published training-content summary under Article 53(1)(d).
9. Retain versioned records of the policy and of the technical measures actually deployed, since these are what an Article 91 information request will target.