The Commission's work programme is a planning document, not a law. It tells you what the executive intends to put on the table and roughly when. This year's edition, reported on by Demócrata, also sets out a review of the Digital Decade 2030 targets and an action plan for spreading AI through strategic industries.
What the Commission adopted
The work programme confirms two things that had until now circulated mainly as draft planning. First, copyright rules are to be adapted to generative AI, with the stated aim of protecting human creators while keeping European technology firms competitive. Second, the number of new legislative files is falling sharply.
According to the work programme, the number of new initiatives is falling compared with recent years, alongside a broader simplification drive.
That combination is unusual. Brussels is preparing a new copyright file at the same time as it promises fewer files overall. The simplification drive is real, but it does not mean the Commission is stepping back from digital regulation.
Copyright and generative AI
The copyright question is the one most people will feel. At present, EU law allows text and data mining for research and commercial purposes, and the 2019 copyright directive lets rights holders reserve their works from that use in an appropriate way, such as machine-readable means. In practice, most individual illustrators, photographers and journalists have no realistic way to attach such a reservation to everything they publish.
That gap is what the 2027 package is meant to address. What form the fix takes is not yet public. The Commission has described the aim, not the mechanism.
What creators' organisations asked for
Pressure has been building through the autumn. In late October, the Spanish reproduction rights organisation CEDRO called for mandatory transparency from AI developers, licensing fees for the use of protected works in training, and penalties where training happens without authorisation.
The Commission has said the aim is protecting human creators while keeping European technology firms competitive. It has not published a mechanism for doing so, and whether CEDRO's specific requests end up in a legislative proposal is a separate matter, to be decided with the European Parliament and the member states.
Where the AI Act stands
The work programme does not replace the AI Act. It sits alongside a rulebook that is already partly in force. Since 2 August 2026, Article 50 applies with full legal effect: synthetic images, audio and video must carry machine-readable marking, deepfakes must be labelled, and chatbots must tell users they are not talking to a person. National market surveillance authorities gained the investigatory and sanctioning powers that go with it.
The high-risk timetable moved in the other direction. Regulation (EU) 2026/1744, the so-called Digital Omnibus on AI, postponed the compliance deadline for standalone Annex III high-risk systems to 2 December 2027, with embedded Annex I products following on 2 August 2028.
So the picture for a European company in November 2026 is uneven. Transparency obligations are live and enforceable. Conformity assessment for high-risk systems has another year. And the copyright rules that would govern training data are still a plan for the second quarter of 2027.
Five sectors named for AI deployment
The accompanying action plan names five areas: healthcare, transport, agriculture and food, advanced manufacturing, and defence and space. These are the fields where the Commission intends to push adoption rather than simply regulate. For a small business in any of them, that could eventually mean access to shared infrastructure, testing facilities or procurement programmes. Nothing specific has been published yet.
What a creator can do now
Little changes this month. The tools exist, though. A photographer or illustrator who wants to check whether their images appear in a training set can use services such as Have I Been Trained, some of which are free. Registering works with a collective management organisation gives a body with legal standing something to negotiate with, which is more than most individuals have.
Our magazine archive has earlier coverage of the AI Act's transparency rules and what they require in practice.
Does the 2027 package change the AI Act?
Not directly. The copyright and simplification package is a separate legislative plan. The AI Act remains in force, with Article 50 transparency duties applicable since 2 August 2026 and the postponed Annex III high-risk deadline of 2 December 2027 set by Regulation (EU) 2026/1744.
When would new copyright rules apply?
No date is set. The Commission aims to present the package in the second quarter of 2027. It would then go through the ordinary legislative procedure with the European Parliament and the Council, which typically takes a year or more, and the final text may differ from the proposal.
Can I stop an AI model from training on my work today?
Under the 2019 copyright directive you can reserve your rights against text and data mining, for example through machine-readable signals or contractual terms. Enforcing that against a large model developer is a different problem, and it is one of the issues the Commission says the 2027 package should address.
