AI Training and Copyright: Toward a Single Opt-Out Registry?

Gianpaolo Todisco Partner

August 2, 2025, the key date for the entry into force of the obligations set forth in the AI ​​Act (EU Regulation 2024/1689), is approaching. By then, providers of generative AI models will be required to ensure copyright compliance in text and data mining (TDM) activities, allowing rights holders to opt out.

But how is this reserve exercised in practice?
Current technical solutions—such as the outdated robots.txt —are unconvincing the cultural sector. More targeted alternatives, such as Spawning or ai.txt , are emerging, but the picture remains fragmented. The recent ruling by the Hamburg Court (Kneschke/LAION, September 27) recognized the validity of an opt-out expressed in natural language, reviving the debate on how to interpret the regulation.

A single opt-out registry?
To bring order, the European Commission is considering creating a central reservations register. It could be managed by the AI ​​Office or the EUIPO and would serve to provide a clear and accessible platform for those wishing to exclude their works from AI model training.

But doubts remain:

  • Who will bear the management costs?

  • Doesn't it risk becoming a bureaucratic obstacle for creators?

  • Why formalize a right already protected by law?

    Innovation yes, but not at the expense of copyright

    Europe is focusing on artificial intelligence, but it must do so while also protecting the work of authors, publishers, and content creators. The solution? Perhaps a simple, shared opt-out standard, without complications or gray areas.

The debate is open. Time is running out.

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