Pre-Hearing Watch — Thomson Reuters v. ROSS (June 11) and GPAI Enforcement (August 2) #
- EU AI Act: GPAI Model Obligations In Force and Final GPAI Code of Practice in Place (Latham & Watkins) — From August 2, 2026 (58 days): Commission enforcement powers enter application. Fines up to €15M or 3% of global annual revenue for non-compliance. GPAI providers must use the EU SEND platform to submit training data summary documents to the AI Office. The training data summary Template (finalised August 2025) is the mandatory disclosure instrument. Three separate August deadlines in one: enforcement powers, training data summary filings, and the SEND platform submission process all activate simultaneously.
- EU Tech Sovereignty Package — Cloud and AI Development Act (European Commission, 2026-06-03) — The CADA creates “levels of sovereignty” for cloud services at EU public-sector organisations. Intersects with training data: organisations subject to CADA sovereignty requirements may face additional constraints on which external cloud-hosted GPAI models they can use for training-data-adjacent tasks — creating a secondary compliance layer on top of the GPAI transparency requirement.
- No new developments in Thomson Reuters v. ROSS since June 2 gather — oral argument remains June 11. No ruling is expected at the argument itself; the Third Circuit typically issues opinions weeks to months after argument.
Cross-links #
- AI Impact on Society EU Tech Sovereignty Package (CADA) is simultaneously a training-data compliance development (restricts which cloud GPAI models public-sector organisations can use) and a sovereignty/independence development (reduces dependence on US cloud providers for AI workloads).
- Open vs Closed AI Ecosystems The SEND platform submission requirement creates a public record of GPAI training data sources — a disclosure asymmetry between closed labs (who must file) and open-weight developers who distributed weights before August 2, 2025 (grandfathered under the 2027 deadline for pre-existing models).
- Quality signal: Latham & Watkins analysis of the simultaneous August 2 triple activation (enforcement powers + training data filing + SEND platform) is the clearest practitioner summary of the compliance deadline structure. The triple-activation on a single date is the key risk for labs that have not yet prepared.
- Gap: No public reporting yet on which GPAI providers have already submitted training data summaries voluntarily ahead of the August 2 deadline. Early filers would be differentiating themselves for enterprise procurement — tracking voluntary compliance rates in the next 60 days would be high-value.