The European Commission (“Commission”) recently launched two stakeholder consultations under the EU AI Act. The first (see here), closing on 9 January 2026, relates to the copyright-related obligations for General Purpose AI (“GPAI”) providers under the AI Act and GPAI Code of Practice. The second (see here), closing on 6 January 2026, seeks feedback on a draft implementing act to establish AI regulatory sandboxes under the AI Act. We summarise key points below.
Consultation on protocols for reserving rights from text and data mining under the AI Act and the GPAI Code of Practice
On 1 December 2025, the Commission launched a stakeholder consultation on technical protocols for expressing reservations of rights against text and data mining (“TDM”). The consultation is intended to support the AI Act’s obligation for providers of general-purpose AI models to put in place a policy to comply with EU law, including to identify and comply with reservations of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790. This is in line with the GPAI Code of Practice, which commits signatories to follow appropriate machine-readable protocols for expressing such reservations, as well as robots.txt and subsequent IETF standards.
Rightsholders, providers of general-purpose AI models, civil society organizations, standardization bodies, and other interested parties are invited to share their views on the technical feasibility and potential uptake of different TDM reservation-of-rights solutions, as identified in the EUIPO study on “Development of Generative Artificial Intelligence from a Copyright Perspective”. The consultation seeks to identify machine-readable, standardised protocols that can be implemented consistently and interoperably across different media, languages, and sectors. By establishing a common technical approach, the Commission aims to ensure that providers of GPAI models can reliably detect and respect rights reservations in a consistent and technically feasible way.
Stakeholders have until the 9January 2026 to respond and can also express interest in participating in workshops organized by the Commission. Signatories to the GPAI Code of Practice (CoP) will be invited by default to these meetings. Following its consultation period, the Commission will publish the list of generally agreed machine-readable reservation-of-rights solutions, which will then be reviewed regularly—at least every two years—in line with updates to the GPAI Code of Practice.
Consultation on draft implementing act to establish AI regulatory sandboxes under the AI Act
On 2 December 2025, the Commission launched a stakeholder consultation on its draft implementing act for the establishment, development, implementation, operation, and supervision of AI regulatory sandboxes. The draft sets out common rules for the establishment and operation of the sandboxes including, among other things, the terms and conditions for participating in the AI sandbox and the application and selection process.
The sandboxes are designed to provide a controlled environment where businesses can test innovative AI systems under regulatory supervision. The sandboxes will support compliance with the AI Act, consistent with Article 57, which requires Member States to establish at least one national AI regulatory sandbox by 2 August, 2026, and will support the objective of the Act to foster AI innovation and support compliance.
Stakeholders have until 6 January 2026, to share their views on the proposed framework, including the criteria for participation, the scope of activities permitted within the sandbox, and the obligations that apply after participation.
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