Commission opens consultation on machine-readable copyright opt-out protocols under the AI Act

The European Commission has opened a consultation on protocols for reserving rights from text and data mining, a key step in implementing the AI Act’s obligation for providers of general-purpose AI models to identify and respect rightsholders’ opt-out signals. The process runs from 1 December 2025 to 23 January 2026 following an extension of the original deadline.

Under the AI Act, providers of general-purpose AI systems must adopt policies to comply with EU copyright rules, including the recognition of machine-readable reservations of rights. The Copyright section of the General-Purpose AI (GPAI) Code of Practice, approved by the Commission as an adequate compliance mechanism, commits signatories to honour relevant opt-out protocols in addition to existing conventions such as robots.txt and its future Internet Engineering Task Force updates.

To support implementation, the Commission seeks to identify a set of state-of-the-art, technically practical, and widely used opt-out solutions that can be recognised across cultural and creative sectors. This work will be conducted with support from the EU Intellectual Property Office and input from a broad set of stakeholders.

The consultation invites rightsholders, GPAI providers, civil society organisations, standardisation bodies, and others to comment on the feasibility and adoption of various text and data mining opt-out mechanisms referenced in an EUIPO study on generative AI. Participants may also express interest in taking part in follow-up workshops aimed at reaching general agreement on a common list of protocols that Code of Practice signatories, and other providers covered by the AI Act, will be expected to respect.

Following these discussions, the Commission will publish a list of agreed machine-readable opt-out solutions, to be reviewed at least every two years in line with updates to the GPAI Code of Practice. An online information session held on 9 December provided stakeholders with further detail on the consultation’s aims, structure, and expected outcomes.

The consultation is available through the Commission’s dedicated portal, which also provides a call for expressions of interest and a set of questions and answers outlining the process.