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CEPIC Feedback to the AI Office on TDM Opt-Out Protocols

Following CEPIC’s participation in the European Commission AI Office workshop on Text and Data Mining (TDM) opt-out protocols held on 2 June 2026, we are sharing our formal feedback submitted to the AI Office, together with the consultation Summary Report.

The workshop forms part of the implementation of Article 53(1)(c) of the AI Act and Measure 1.3 of the General-Purpose AI Code of Practice’s Copyright Chapter, which focuses on how providers of General-Purpose AI models identify and respect machine-readable rights reservations (TDM opt-outs) expressed by rightsholders.

In its submission, CEPIC welcomes the Commission’s work and underlines the importance of recognising IPTC metadata as an established and effective opt-out mechanism alongside other shortlisted solutions.

CEPIC’s position is that IPTC should not be treated as a secondary or sector-specific standard. For more than 20 years, IPTC has enabled rights information to travel directly with visual assets and remains deeply embedded across the news, photography and image licensing sectors. In practice, this makes IPTC a complementary and highly practical solution alongside location-based approaches such as robots.txt and TDMRep, as well as provenance frameworks such as C2PA and future initiatives including JPEG Trust.

CEPIC also highlights that existing, functioning standards should be recognised and supported to avoid unnecessary delays in implementation while ensuring that rightsholders’ rights and revenues are respected.

Documents available to members:

CEPIC Feedback Letter to the AI Office

Summary Report – Stakeholder consultation and call for expression of interest supporting implementation of Article 53(1)(c) of the AI Act and Measure 1.3 of the GPAI Code of Practice Copyright Chapter

We will continue to keep members informed as discussions progress and additional guidance or outcomes are published.

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