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On 3 February 2025, the European Commission (“EC”) published an updated version of its frequently asked questions (“FAQs”) on the EU Data Act.[1]  The Data Act, which is intended to make data more accessible to users of IoT devices in the EU, entered into force on 11 January 2024 and will become generally applicable as of 12 September 2025.

On 5 September  2024, the EU, UK and US joined seven other states[1] in signing the Council of Europe Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law (“Treaty”) – the first international treaty governing the safe use of artificial intelligence (‘‘AI’’).[2] The Treaty remains subject to ratification, acceptance or approval by each signatory and will enter into force on the first day of the month following a period of three months after the date on which five signatories, including at least three Council of Europe member states, have ratified it. Any state worldwide is eligible to join the Treaty, subject to the unanimous approval of the signatories, and to commit to complying with its provisions. The Treaty is expected to have a positive impact on international cooperation on addressing AI-related risks.

On 2 July, the French data protection supervisory authority – Commission Nationale de l’Informatique et des Libertés (CNIL) – launched a new public consultation on the development of AI systems. The public consultation is on (i) a new series of how-to sheets aimed at providing clarifications and recommendations with respect to seven issues related to the development of AI and data protection and (ii) a questionnaire on applying the GDPR to AI models trained with personal data. Below we set out a summary of the main takeaways.

1. Background: three years of legislative debate

Today, on July 12, 2024, EU Regulation No. 1689/2024 laying down harmonized rules on Artificial Intelligence (“Regulation” or “AI Act”) was finally published in the EU Official Journal and will enter into force on August 1, 2024.  This milestone is the culmination of three years of legislative debate since the EU Commission’s first proposal for a comprehensive EU regulation on AI in April 2021. [1]

On 15 January 2024, the UK Information Commissioner’s Office (“ICO”)[1] launched a series of public consultations on the applicability of data protection laws to the development and use of generative artificial intelligence (“GenAI”). The ICO is seeking comments from “all stakeholders with an interest in GenAI”, including developers, users, legal advisors and consultants.[2]

This third part of our four-part series on using synthetic data to train AI models explores the interplay between synthetic data training sets, the EU Copyright Directive and the forthcoming EU AI Act.

This second part of our four-part series on using synthetic data to train AI models explores how the use of synthetic data training sets may mitigate copyright infringement risks under EU law.