Voluntary, but Consequential
New EU Code of Conduct for AI:
Blessing or Bureaucratic Monster?
The EU Commission promises more legal certainty and less bureaucracy in implementing the AI Act with a new code of conduct for general-purpose AI. But while Brussels speaks of a milestone, German digital industry warns of new hurdles and legal uncertainties.
1. What Is the 'Code of Practice'?
On July 10, 2025, the European Commission presented the final code of conduct for general-purpose AI models (GPAI).
The key advantage for companies: Providers who sign and follow the code benefit from greater legal certainty and reduced administrative burden.
2. Three Chapters for Clear Rules
The code is divided into three separate chapters addressing different aspects of the AI Act.
- Transparency
Provides a form for model documentation to easily and structurally fulfill obligations under Article 53 AI Act.
- Copyright
Shows practical solutions for an EU-compliant copyright policy, especially for publicly available data.
- Security & Protection
Targets models with systemic risks (Article 55 AI Act) and describes procedures for managing these risks.
3. Criticism from Industry: Bitkom Warns
Although digital association Bitkom generally welcomes the publication as an opportunity for greater legal certainty, there are significant concerns.
Bitkom's Main Points of Criticism:
Legal Uncertainty Through 'Open-Ended Risk Assessment'
The obligation for high-performance model providers to identify potentially only conceivable, hypothetical risks is seen as problematic.
High Bureaucratic Burden
Documentation requirements for handling rights holder complaints are criticized as too bureaucratic and burdensome.
Are You Ready for the AI Act?
The new code of conduct raises questions. Whether you're looking for comprehensive compliance security or have a specific question – we're here to help.
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