EU AI Act Annex XI: energy must be documented, not disclosed
The obligation
The EU AI Act's rules for general-purpose AI models began to apply on 2 August 2025. Annex XI sets out the technical documentation a provider must prepare and keep up to date, and among the items it lists is the model's energy consumption: the known or estimated energy used in training. The provider must be able to supply it to the European AI Office and to national authorities on request.
What "known or estimated" means
The text allows an estimate where measurement is not available, and the drafting anticipates that estimates will be based on compute: the number of operations the training run required, converted to energy by assumptions about hardware and efficiency. That is roughly how the index estimates training footprints for companies that publish nothing. The difference is that the index publishes its working. The Act does not require the provider to publish anything.
What it does not cover
Inference, which is where most of the electricity of a deployed model goes; water, in any form; the embodied carbon of hardware; the grid on which the model was trained, so an estimate in kilowatt-hours carries no emissions figure. The Green Software Foundation and others have argued for a carbon-intensity metric to sit alongside energy. The Act does not provide one.
The code of practice
The General-Purpose AI Code of Practice, published in July 2025 as a voluntary route to compliance, includes a model documentation form with an energy field. Signing it is optional; the documentation remains confidential to regulators. Mistral's life-cycle assessment, published the same month, shows what a public version would look like: absolute training impact, marginal inference impact, and the ratio between them, across carbon, water and minerals.
Why the index exists in the gap
A regulation that requires documentation but not disclosure produces compliance without information. The index's disclosure checklist asks for the things the Act does not: per-prompt energy and water, training emissions in model cards, a public annual report, location-based Scope 2, fleet WUE, third-party review and hardware circularity. Only Google and Mistral come close. The Act, as written, would not have changed a single score.
Companies in this post
Sources
- 1.EU AI Act — Annex XI: technical documentation for general-purpose AI modelsartificialintelligenceact.eu · Jul 12, 2024
- 2.General-Purpose AI Code of PracticeEuropean Commission (via artificialintelligenceact.eu) · Jul 10, 2025
- 3.SCI for AI and the EU AI ActGreen Software Foundation · Mar 1, 2025
- 4.Our contribution to a global environmental standard for AIMistral AI · Jul 22, 2025
Figures labelled as estimates on the index carry roughly ±3× uncertainty; disclosed figures are the company’s own. Corrections: team@ecogpt.com.



