Adopt a copyright-compliance policy: Which control is missing?
Open licensing is conditional and does not excuse the missing copyright-compliance policy for the applicable GPAI provider.
The question
For software procurement in the European Union, assume a vendor’s open-licensed general-purpose model is otherwise subject to all applicable EU AI Act duties. The model documentation, downstream information, and public training-content summary are complete, but the provider has no policy addressing copyright compliance. Which control is missing?
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- Limit procurement to models used without downstream providers.Downstream-provider information is already complete, and eliminating downstream use is unnecessary for the stated missing control.
- Adopt a copyright-compliance policy. ✓Open licensing does not remove the applicable copyright-compliance policy requirement for a general-purpose AI model provider.
- Require a new conformity assessment for the licensed model.The facts concern general-purpose model duties, not a stated high-risk-system conformity-assessment gap created by procurement.
- Replace the open license with a proprietary license.Changing licensing terms does not itself create the required copyright-compliance policy or resolve the identified governance gap.
The trap
Do not treat an open license as a complete regulatory exemption; inspect each applicable GPAI duty independently. How to remember it
Open licensing is conditional and does not excuse the missing copyright-compliance policy for the applicable GPAI provider.
How many of these would you get right?
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