EU AI Act obligations begin: energy use must be documented, estimates allowed, disclosure optional

From 2 August 2025 providers of general-purpose AI models must keep technical documentation under Annex XI of the EU AI Act, including the model's energy consumption. Where consumption is unknown, an estimate based on computational resources is acceptable.

The General-Purpose AI Code of Practice turns this into a standardised Model Documentation Form covering compute and energy, retained for at least ten years. Public disclosure is encouraged, not required, and free open-source models are exempt unless they pose systemic risk.

The Green Software Foundation argues the regime stops short: no mandated measurement of actual emissions, no embodied-hardware emissions, no public reporting, no common methodology before harmonised standards arrive — possibly not until 2028. The index therefore keeps its own transparency checklist rather than relying on regulatory filings.