Back to news

Artificial Intelligence Hub

December 19, 2025

European Commission Consults on Copyright Compliance and AI Regulatory Sandboxes under the EU AI Act

European Commission launches consultations on AI Act implementation, covering copyright compliance for GPAI models and rules for AI regulatory sandboxes.

The European Commission has launched two parallel stakeholder consultations connected to the implementation of the <span class="news-text_italic-underline">EU Artificial Intelligence Act</span> (the “<span class="news-text_medium">AI Act</span>”). The consultations address copyright compliance for general-purpose AI models and the operational framework for AI regulatory sandboxes.

Copyright and text and data mining reservations

On 1 December 2025, the Commission opened a <a href="https://digital-strategy.ec.europa.eu/en/consultations/commission-launches-consultation-protocols-reserving-rights-text-and-data-mining-under-ai-act-and" target="_blank" class="news-text_link">consultation</a> on technical protocols for expressing reservations of rights against text and data mining. The initiative supports obligations under the <span class="news-text_italic-underline">AI Act</span>  requiring providers of general-purpose AI models to maintain policies ensuring compliance with EU law including the identification and observance of rights reservations made under Article 4(3) of <span class="news-text_italic-underline">Directive (EU) 2019/790</span>.

The consultation aligns with the General-Purpose AI Code of Practice which commits signatories to apply appropriate machine-readable protocols for expressing reservations of rights alongside tools such as robots.txt and related IETF standards.

Rightsholders general-purpose AI providers civil society organisations standardisation bodies and other stakeholders are invited to comment on the technical feasibility interoperability and likely uptake of different reservation-of-rights solutions. The Commission draws on findings from an European Union Intellectual Property Office study on the development of generative AI from a copyright perspective and seeks to identify standardised machine-readable solutions that can operate consistently across media formats languages and sectors.

Responses must be submitted by 9 January 2026. Stakeholders may also indicate interest in participating in Commission-led workshops. Signatories to the Code of Practice will be invited automatically. Following the consultation the Commission will publish a list of generally accepted machine-readable reservation-of-rights solutions which will be reviewed at least every two years in line with updates to the Code of Practice.

AI regulatory sandboxes

On 2 December 2025, the Commission launched a separate consultation on a draft implementing act establishing rules for AI regulatory sandboxes under the <span class="news-text_italic-underline">AI Act</span>. The draft sets out common requirements governing the creation operation supervision and participation conditions of national AI sandboxes.

The sandboxes are intended to provide a controlled regulatory environment in which businesses can test innovative AI systems under the supervision of competent authorities. They are designed to support compliance with the <span class="news-text_italic-underline">AI Act</span> and to promote innovation in line with Article 57 which requires each Member State to establish at least one national AI regulatory sandbox by 2 August 2026.

Stakeholders are invited to comment on eligibility criteria application and selection procedures the scope of permitted activities within the sandbox and the obligations that apply following participation. Submissions must be made by 6 January 2026.

These consultations mark an important step in shaping how copyright compliance and innovation support mechanisms will operate in practice under the <span class="news-text_italic-underline">AI Act</span> particularly for developers and deployers of general-purpose AI systems.

Address
London:
2 Eaton Gate
London SW1W 9BJ
New York:
295 Madison Avenue 12th Floor
New York City, NY 10017
Paris:
56 Avenue Kléber
75116 Paris
BELGRAVIA LAW LIMITED is registered with the Solicitors Regulation Authority with SRA number 8004056 and is a limited company registered in England & Wales with company number 14815978. The firm’s registered office is at 2 Eaton Gate, Belgravia, London SW1W 9BJ.

‘Belgravia Law’ (c) 2025. All rights reserved.
By clicking “Accept”, you agree to the storing of cookies on your device to enhance site navigation, analyse site usage, and assist in our marketing efforts. View our Privacy Policy and Cookie Policy for more information.