Think of the last thing you put on the open web and left there. A recipe with a little too much story above it. An answer you typed out for a stranger on a forum. A blog you kept up for two years and then didn't. The few pages of a small business's website, written in an evening and never touched again. (If you've never published a word online, someone you know has. Read this for them.)
Did an AI company's crawler pass through it? Did a model learn from it? Europe wrote a rule that was supposed to give people like you a place to start looking — and the instruction at its center fits in one sentence.
It sits in Section 2.3 of the European Commission's template for the public summaries AI companies must publish about their training data, and the Commission's FAQ leaves no room for doubt: "using the Template is mandatory." The sentence tells each company to "provide a list of those most relevant internet domains names (top and second-level domain, e.g. “example.com”) by listing the top 10 % of all domain names determined by the size of the content scraped." The form even suggests a format: "You can provide this list for instance as a downloadable file or provide here information on how to access it."
Who was it for? The Commission's explanatory notice says this kind of transparency "should help rightsholders obtain relevant information on the content used in the training of general-purpose AI models." If the words you posted are your own, that sentence is about you.
So I read what six of the biggest AI developers put in that box: OpenAI, Google, Anthropic, Meta, Microsoft and xAI. (A disclosure: this piece was drafted with help from Anthropic's Claude.) Of the 48 documents I read from those six, 36 have the box (Microsoft's older cards use a layout without it). In 33, it describes kinds of sites or points somewhere else: "community and general-interest sites," "public reference platforms," "math sites" and, from Meta, a pointer to a page about its crawlers. Microsoft's lists "blogging and personal-publishing platforms" among its top 10 percent, without naming one. In the other three, all filed by xAI in August and September, the box names one site, "X social media platform," as the newest puts it. The company behind those summaries owns the social network X.
That is the whole tally as of October 13, 2026. Europe asked for the biggest tenth of the domains each company scraped, with "example.com" as the model answer. Between them, six of the largest companies in the business have put one site in that box — and it belongs to the company that filed it.
None of this tells you whether your work was used. The summaries don't say that about any site, in either direction.
A law that leaves the detail to a form
Start with the law. Article 53 of the EU's AI Act requires every provider of a general-purpose AI model to "draw up and make publicly available a sufficiently detailed summary about the content used for training of the general-purpose AI model, according to a template provided by the AI Office." (General-purpose models are the large ones underneath chatbots and image generators; the AI Office is the Commission's enforcer for these rules.) What counts as "sufficiently detailed," in other words, is settled by the form.
The Commission published the template in July 2025 as what it calls a common minimal baseline. The duty itself has applied since August 2, 2025, with the exception of Article 101 — the fines — which waited a year. (I noted this carve-out for the fining power over general-purpose AI models in August.) Since August 2, 2026, the Commission can impose fines not exceeding 3 percent of a company's worldwide annual turnover, or €15 million, whichever is higher. Each summary is supposed to be updated "at six-month intervals," or sooner after a materially significant change. And the Digital Omnibus on AI, which moved one of the law's deadlines in July, left Article 53 untouched.
Inside Section 2.3, the part of the form for data crawled and scraped from online sources, is the box this piece is about. Its instruction is the sentence above: the domains, at the level of "example.com," that make up the top 10 percent of everything scraped, measured by size. (Smaller companies may stop at the "top 5% of all domain names or 1 000 internet domain names, whichever is lower.") The notice's own footnote says Section 2.3 "requires a list of the internet domain names."
So far so good: a rule, a form and a sentence plain enough to follow. What did the six companies write?
Six companies, one box
Below is one recent summary from each company, as of October 13, 2026, and what it says in that box.
OpenAI, GPT-6 Astra (dated September 2, 2026): "The most relevant crawled source domains include academic, research, patent, and other technical repositories, legal and government resources, document-hosting and sharing services, community and general-interest sites, and region-specific portals." OpenAI's other summaries repeat the same list, except the one for its Images 2.0 model, which lists other categories.
Google, the Gemini 4 family (dated October 13, 2026): "The most relevant domains crawled include publicly available websites across educational, government, legal, and research sectors, such as open web sources and public reference platforms that are maintained for research and educational purposes." It adds "top-level domains such as .com, .org, and .edu." Google's summaries for Gemini 3 and Gemma 4 also describe websites across educational, government, legal, and research sectors.
Anthropic, Claude Opus 5.5 (dated September 22, 2026): "Data used in model training which is derived from data crawled and scraped from online sources includes technical documentation, open-source software, predominantly text-based reference sites, document sharing sites, and math sites." It adds that "Top-level domains such as .com, .org, and .net are included alongside sites from a range of different countries." All ten of Anthropic's model summaries list the same categories.
Meta, Muse Wonder (dated October 12, 2026): "See the developer center resource linked above for more information about Meta's web crawlers." The page it points to says the Meta-ExternalAgent crawler crawls the web for uses "such as training foundation AI models," and it lists Meta's crawlers and robots.txt rules. It lists no domains. Meta's reports for Muse Spark, Muse Image and Muse Glimmer give the same pointer.
Microsoft, MAI-Thinking-1 (dated August 12, 2026): "The top 10% domains by volume crawled and used to train MAI-Thinking-1 span a broad mix of content types." It goes on to "publicly available reference and knowledge sites, blogging and personal-publishing platforms, social and professional networks," and eight more kinds, adds that "General web hosting, blogging, social, and e-commerce platforms make up a large share of the total," and lists country codes from .jp to .nz. Microsoft's other recent MAI cards use the same formula or, for image models, a similar list of categories.
xAI, Grok 4.7 (dated September 21, 2026, and filed under the company's new name, SpaceXAI LLC): "Crawled sources include certain data from content hosting and content sharing services, like X social media platform, educational repositories, government and institutional resources, community and document-sharing sites, and region-specific portals." Its August summaries, for an update to Grok 4.5 and for Grok Imagine Image 2.0, name "the X social media platform" in the same place. Its July summaries named no site.
Read side by side, the six answers sound like one answer. Microsoft's is the most descriptive, and it names no site; neither do OpenAI's, Google's, Anthropic's or Meta's. xAI's names one — X.
To be fair to all six, these documents aren't empty. Elsewhere in them, most of the companies name names. OpenAI says GPT-6 Astra's training data "includes text from Common Crawl." Anthropic's lists datasets "notably including Common Crawl." Microsoft names "GitHub public repositories, Wikipedia, and CommonCrawl." Meta names "publicly shared posts from Instagram and Facebook." xAI names "Common Corpus (Pleias), OpenAlex metadata, and Crossref metadata." Google's describes Google-Extended, a control for web publishers. (I described Google-Extended in August as a product token publishers put in robots.txt.) Most also name their crawlers. So the companies can name things when the form asks. In the one box that would tell you whether your corner of the web was among their biggest sources, they wrote kinds of sites — and, in xAI's case, its own platform.
Others, reading other sets of summaries, found the same thing. ActuIA, a French AI news site, compared 24 summaries in September and found that "21 include this section and none name a site," although its sample included two OpenAI summaries and none from the other five companies here. On August 7, the AI Accountability Lab, a research group that tracks these summaries (its work has received Mozilla Foundation funding), wrote that "despite template explicitly asking for domains crawled, no provider has indicated which specific websites they crawl." Its list either predates or missed the three xAI summaries that name X.
Even a perfect list would leave you guessing
Would a fully filled-in box tell you whether your work was used? No. Why? Because the form limits what it can show, in four ways.
First, it leaves out the big shared collections. The domain list excludes "publicly available datasets already compiled by third parties and made available on platforms such as common crawl that are covered under Section 2.1." (Common Crawl publishes archives of crawled web pages; three of the six summaries quoted above name it.) Section 2.1 only requires naming "large" datasets, those above 3 percent of all the publicly available data used for a given kind of content, and even there, the AI Accountability Lab found, providers "rarely indicate which snapshots were used in the training of their model."
Second, it stops at the domain. The template asks for "top and second-level domain," so a blog hosted on a big platform would show up, at most, as the platform.
Third, it stops at the top tenth, by volume. Whether a small site makes the cut depends on how much else was scraped.
Fourth, the regulator won't go work by work. The notice says the AI Office may check whether the template was filled in correctly "without performing a work-by-work assessment or checks whether specific content has been used or not."
In short, a perfect box could tell you that your domain was among one company's largest sources. It couldn't tell you that your post was read, or which model learned from it. The box was only ever a starting point — and the starting point is what's missing.
Isn't a summary supposed to summarize?
It's a fair question, and the companies have a better answer than you might expect.
Start with the law's own preamble. Recital 107 of the AI Act, which the Commission's notice quotes, says the summary "should be generally comprehensive in its scope instead of technically detailed," so that parties with legitimate interests, "including copyright holders," can enforce their rights. (Recitals are the paragraphs at the top of an EU law that explain what its articles are for.)
Then the notice describes Section 2.3 in its own words: "the Template requires a disclosure of a summary of the list of top domain names crawled and scraped from online sources in a summarised narrative form." In the same paragraph, it says the template "does not require disclosure of the details for the specific data and works used to train the model." Four paragraphs on, it describes the box as striking "a balance with the trade secrets ensuring the Summary remains non-technical and in a summarised narrative form." A summary of a list, then, in narrative form. Read that way, "community and general-interest sites" is an answer.
The industry asked for exactly this before the template existed. In January 2025, CCIA, a tech-industry trade group, put out its own model template, arguing that "transparency measures may not compromise AI model safety, trade secrets, or confidential business information" and that "The information should be provided in narrative form," with sources described in categories such as "public web scraping of internet websites." The six answers in the box read a lot like what CCIA proposed (that comparison is mine, not CCIA's).
And the stakes, as xAI tells it, are real. In its California case, xAI argues that "If xAI revealed details about its datasets, competitors would immediately move to acquire the sources xAI uses that its competitors lack to ensure that their models match xAI's." That's an argument in a brief, but it puts the trade-secret worry plainly.
Has anyone with the power to decide ruled that these answers fall short? Not as of October 13, 2026. As ActuIA put it, "Whether these sections satisfy Article 53 is for the Commission to decide." Euractiv reported on August 7 that "The AI Office has flagged deficiencies in some training disclosures," without naming them in the part of the story outside its paywall. On August 26, Euractiv's Maximilian Henning reported the Commission's first use of its new enforcement powers and that, separately, its enforcers had asked "more than 30 AI companies to detail how they're complying with European copyright rules," and, citing Commissioner Henna Virkkunen, that the Commission had approached developers "that failed to publish the training data form or had not responded to informal inquiries about copyright compliance." The copyright requests, as reported, were about missing forms and unanswered questions. I found no reporting that ties them to forms filled in with categories.
So are the companies breaking the rule? I won't say so, and no one with the authority to decide has ruled that they are. My point is narrower. The narrative-form language and the list instruction sit in the same document. The notice that allows "a summarised narrative form" also says, in a footnote, that the box "requires a list of the internet domain names," and the form's own instruction says "provide a list," uses "example.com" as its example and offers "a downloadable file" as one way to deliver it. A summary of a list is a summary of something. The six published the summary. None of them published the list.
That's why I call these answers non-specific rather than unlawful. Whether non-specific is enough is the Commission's call, and as of October 13, 2026, it hasn't made it.
California asks a smaller question and gets the same answer
Is this a European problem, or a disclosure problem? California offers a test, because the same six companies face a looser version of the same question there.
California's training-data law, AB 2013, now Section 3111 of the state's Civil Code, requires a developer to post "documentation regarding the data used by the developer to train" a generative AI system, beginning with "(a) A high-level summary of the datasets." The first of its twelve items is "(1) The sources or owners of the datasets." The twelve never ask for a website, a domain or a URL. Europe asked for domains and got categories. California asks for sources. What did the same companies post?
OpenAI's "Training Data Summary Pursuant to California Civil Code Section 3111" says: "We develop these systems using a variety of data sources, including publicly available data, data that we partner with third parties to access, and information that our users or human trainers and researchers provide or generate." It names no dataset, crawler or site; its EU summary names Common Crawl and GPTBot.
Google posted one summary, dated June 1, 2026, for 23 of its products, from Ads to YouTube. Its sources include "publicly available datasets, licensed data obtained via commercial licensing agreements, data obtained by crawlers, data collected from our users and also user interactions with the models."
Anthropic's "Training Data Documentation," dated December 2025, says "Claude models are trained on a proprietary mix of data from the following source categories" and lists five, including "Publicly Available Internet Data: Content from publicly accessible repositories as well as content crawled from the public web." It names no dataset, crawler or site; its EU summary names Common Crawl and ClaudeBot.
Meta's page "AI at Meta: Transparency about our training data" answers, one by one, the twelve questions California's law asks, without naming the law. Its sources: "a mix of publicly available data, licensed data and information from Meta's products and services," including "publicly shared posts from Instagram and Facebook and people's interactions with AI at Meta features."
Microsoft: I couldn't find a page labeled for California's law when I searched on October 13, 2026, which isn't the same as Microsoft not having posted one. Its general "Data for AI model development" page says: "We train on select publicly available data, from a mix of industry-standard machine learning datasets and web crawls."
xAI, the sixth, is the one that sued. I wrote in September about how it went to court to establish that the state can't make it post more than the page it put up the day after it sued, so I won't re-argue the First Amendment question here. Where things stand as of October 13, 2026: a federal judge denied the preliminary injunction on March 4, 2026; in the Ninth Circuit, the appeal is scheduled for oral argument on November 18, 2026, in Pasadena. (The court's notice adds that "the panel may decide to submit the case on the briefs instead.") There's no decision.
As for xAI's own California page, posted on December 30, 2025, the court's order quotes the company calling it a "high-level, limited disclosure" "that does not reveal its trade secrets." I couldn't find it among the documents on xAI's legal page on October 13, 2026, so I'll leave its contents at the company's own description. One line in xAI's reply brief echoes Europe, though: California, it says, "refuses to disavow enforcement against xAI or take a position—even at the district court's request—on whether xAI's disclosures suffice." That's how xAI describes the state's position.
Side by side, a few things stand out. Europe's stricter form drew out more names from some of these companies: OpenAI names Common Crawl and GPTBot in Europe and neither in California, and Anthropic names Common Crawl and ClaudeBot in Europe and neither in California, while Meta names Instagram and Facebook posts in both. But in the one box built for people with websites, Europe's answers look like California's: kinds of sources rather than sources. And as of October 13, 2026, neither regulator has ruled on whether that's enough — the AI Office hasn't, and California, by xAI's account, won't say.
Stanford researchers who compared the California documents from OpenAI, Google and Anthropic, in a paper posted in January, found that they varied in detail and concluded that "none of these disclosures are specific enough to guarantee protection of personal data and copyright, nor do they provide enough information for actionable change to training data practices."
Now picture the file attached
Everything in this section is my extrapolation, not a forecast about any company. It wouldn't take a new law, either; the hooks are already in the documents.
Picture it from your side first. A summary update arrives with a file attached in Section 2.3, the way the template suggests, and you search it for your domain. Maybe it's there. Maybe your platform is, with you somewhere inside it. Maybe there's nothing. Even an empty search would tell you something you can't learn now.
Picture the six-month diff. Summaries are supposed to be updated "at six-month intervals," and xAI's wording has already changed once, between July and August, when "the X social media platform" appeared in the box. Imagine publishers, researchers and reporters reading these documents the way programmers read software changelogs: lining up each version against the last and asking what appeared, what vanished and why. With updates twice a year, a category that quietly drops out becomes a story.
Picture the first request for the real list. The AI Act lets the Commission ask a provider for its documentation "or any additional information that is necessary for the purpose of assessing compliance," and ask providers to "take appropriate measures to comply with the obligations set out in Articles 53 and 54." Imagine the first such request asking not for a better paragraph but for the file the template already describes. (No such request has been reported as of October 13, 2026.)
Picture the template revised. The Commission says it "will monitor the implementation of the Template" and "where necessary review the Notice and the Template." Imagine a version in which the downloadable file is the default and the paragraph is the footnote. It could go the other way, too. The Commission's open copyright consultation asks people to rank options it says it hasn't endorsed. One would have companies share information under a nondisclosure agreement, on a rights holder's substantiated request, "as an alternative to the public disclosure of the top 10% of the top domain names."
Picture a lookup that joins the pieces. The public crawl archives and the summaries that name them are already out there (the list below points to both). Imagine one screen that tells a recipe blogger which crawls captured their site and which models' summaries name those crawls. Joining the pieces is the part no one has been required to do.
Picture Pasadena. Whenever the Ninth Circuit rules, the case can go two ways. In one, California's law survives — including its first item, "The sources or owners of the datasets" — and the next fight is over whether a category counts as a source. In the other, a ruling for xAI unsettles even that item.
Who saw this coming, and who thinks it's fine
The warnings came early. On July 30, 2025, six days after the template came out, Zuzanna Warso of Open Future, a European open-knowledge group, wrote that the template's language "could be interpreted as requiring only the top 10% overall—a single aggregated list that could completely obscure modality-specific sources." Where the form settles for "general descriptions" of data processing, she warned, "This opens the door to corporate boilerplate and essentially meaningless responses." Her advice: "if the first wave of disclosures proves superficial, the AI Office must be ready to correct course quickly."
The same day, a coalition of rights-holder groups (authors, performers, publishers, producers) rejected any claim that the template "will deliver “sufficient” transparency about the majority of copyright works." Its verdict: "This is simply untrue and is a betrayal of the EU AI Act's objectives."
A year on, the people reading the first summaries found the kind of answers those groups had warned about. ActuIA's version: "A category such as general knowledge resources does not allow them to find their own domain, nor to conclude that it was used or that the collection was unlawful." The AI Accountability Lab's, from an August 31 post on public datasets: providers are "answering a question analogous to “where did you get this information?” with a generic “the internet”" (a line worth pinning above the whole exercise).
On the other side, the case for less detail rests on trade secrets, in CCIA's proposal and xAI's brief, both quoted above. The regulator, so far, has talked about process: not every developer of the "most advanced" models got its request for information, Virkkunen said, as Euractiv quoted her, "because, with some of them, we have already had very close dialogue during the last months."
California's law, meanwhile, has defenders you might not expect. The Knight First Amendment Institute, a free-speech group, told the Ninth Circuit that "These disclosures are undisputedly factual, noncontroversial, and related to xAI's commercial products." (xAI disputes exactly that.) Tyler Whitmer and Ben Rashkovich of LASST, an AI-safety legal advocacy group, called the law "the functional equivalent of an ingredient label" in a July op-ed. And the AI Coalition for Data Integrity, developers and creators who license data (its brief's co-signers include John Wiley & Sons and the National Association of Voice Actors), put the licensing market's view in two sentences: "The developers that suffer no injury from these disclosures are the ones that obtained their data lawfully. That is the point."
Line them up and the alliances are unusual. Rights holders and open-knowledge advocates warned of thin answers; accountability researchers found category answers. The industry asked for narrative form before the form existed. A free-speech institute is defending a disclosure mandate. (One gap, in fairness: I looked for a free-market think tank's view of Europe's domain box and didn't find one, so the case for less disclosure is made here, in their own words, by the industry's trade group and by xAI.)
What does this mean for you?
Nothing below will tell you whether a particular page of yours trained a particular model; the documents don't say that about any site. But there's plenty you can check.
Read the box for the models you use. It's Section 2.3, on data crawled and scraped from online sources. OpenAI publishes summaries about the content used to train its models on one help page. Google posts its summaries as downloadable reports on its transparency report site. Anthropic keeps its training data summaries in its trust center. Meta's sit on its regulatory transparency reports page, and Microsoft's MAI data summaries on its own site. xAI lists its public summaries of training content on its legal page. Expect categories, not names.
Search Common Crawl yourself. Its index server lets you search the CDX URL index for any of its archives by entering "a URL pattern." Two cautions. Common Crawl calls its dataset "a sample of the web" and says it does not generally archive any entire website, only "a randomly selected subset" of one, so not finding your page proves little. And finding it doesn't show that any model trained on that snapshot.
Opt out going forward, crawler by crawler. These signals say what may be collected or trained on from here on.
OpenAI: "Disallowing GPTBot indicates a site's content should not be used in training generative AI foundation models."
Anthropic: blocking ClaudeBot (
User-agent: ClaudeBot) signals that a site's "future materials should be excluded."Google: Google-Extended is "a standalone product token" for Gemini training, and Google says it doesn't affect your site's place in Search.
Meta: Meta-ExternalAgent is the training crawler; to block it, "add a disallow for the relevant crawler to robots.txt."
Microsoft: the MAI-Thinking-1 summary names Bingbot, which, it says, indexes web content "for both search and model training." Bing said in 2023 that content labeled NOARCHIVE won't be used "for training Microsoft's generative AI foundation models" and "will still appear in our search results." (By that logic, blocking Bingbot outright would also take you out of Bing search.)
Common Crawl: two lines,
User-agent: CCBotandDisallow: /, and "our crawler will stop crawling your website."xAI: Grok 4.7's summary names a "SpaceXAI Web Crawler" and says SpaceXAI "respects instructions that identified crawled content should not be used to train" its models, but as of October 13, 2026, I found no robots.txt name for that crawler published by xAI.
If you're in the EU and hold rights in your work, you can ask, and complain, within limits. The Commission recommends that providers "act in good faith and on a voluntary basis" and tell rights holders, "upon requests," whether they scraped and used content from "specific internet domains." It's a recommendation; nothing in the notice obliges a company to answer. Companies that signed Europe's code of practice committed to "designate a point of contact" for rights holders and to take complaints, though those complaints concern a signatory's "non-compliance ... with their commitments" under the code, not whether your site was used. As of the code page's October 7, 2026 update, Anthropic, Google, Microsoft and OpenAI are signatories; xAI signed up to the Safety and Security Chapter only; and Meta isn't listed.
Tell the Commission what you want in that box, by November 3, 2026. Its targeted consultation on copyright and AI takes answers from individual authors as well as companies, and one option would replace the public list with private disclosure to rights holders. If you want the list public, say so there.
If you're in California, the law asks for "the sources or owners of the datasets," and the pages above show what that has produced so far. Watch November 18, 2026, in Pasadena.
The lesson, as I see it
A form is a promise about what you'll get to see. Europe's promised a list, gave "example.com" as the model and suggested a downloadable file. From six of the biggest companies in the business, it got well-made paragraphs and one name — which belongs to the company that wrote it.
The law allows paragraphs, and I've tried to give the companies' reading its full weight. But a rule written to help people who publish online learn what went into these models shouldn't stop at a list of kinds. Categories describe the web. Names would describe what was scraped from it.
The good news is that the answers can change without a new law. Every summary is due for an update every six months. The Commission has been able to fine since August 2, 2026, and it can ask for more. Until November 3, it's also asking whether private disclosure to rights holders should replace the public list. xAI's challenge to California's law is set for argument in the Ninth Circuit on November 18. And models already on the market before the rules have until August 2, 2027 to comply, which means a second wave of summaries is coming, for the models people have used longest. It can arrive with lists attached, or the way this one did.
My vote? Ask for the file. The template already has a place for it.
Somewhere in your contacts is someone with a recipe blog, a forum handle with years of answers behind it, or a shop website they built themselves. Send them this. Section 2.3 was written with people like them in mind, and they deserve to know what's in it.