Dear European AI Office, Unit Artificial Intelligence Regulation and Compliance (CNECT.A.2),

Under the right of access to documents in Article 15 Treaty on the Functioning of the European Union and Article 42 Charter of Fundamental Rights, as developed in Regulation 1049/2001 on Public Access to Documents, I am kindly requesting documents that contain the following information on the implementation of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 (hereinafter, ‘AI Act’):

- Overall list of individual academic researchers and other experts who participated in the drafting of the General-Purpose AI Code of Practice. I do not mean here the chairs and vice-chairs of the different working groups, but those researchers and experts who contributed with submissions to the drafting of the code of practice throughout its different stages;

- Any document(s) stating the list of participating organisations, researchers and experts for each of the four rounds of drafting of the code. These documents could be either general lists of participants eventually compiled at the start or end of each drafting round, or, alternatively, general summaries or lists related to the workshops, working group meetings and plenaries of each drafting round;

- Powerpoint presentation summarising the applications and selection process shared with the plenary of the stakeholders at the beginning of the drafting process;

- Notes, briefs, presentations or any other similar document containing the results of any EU surveys launched for participant feedback during the drafting process of the code (such as the EU Survey launched on December 19th 2024, as is indicated publicly on the European Commission’s website);

- Meeting summaries, meeting notes, briefs, presentations, or public procurement documentation, or any other similar document containing the tasks of Intellera Consulting and Wavestone related to the support of the drafting of the code of practice. Such documents can be redacted to only mention the tasks and their respective descriptions; this request is not meant to cover confidential contractual information;

- Submissions to the public consultation of 30 July 2024 on the Code of Practice for general-purpose Artificial Intelligence that provide feedback on systemic risk identification, assessment and mitigation.

To provide context, I am requesting these documents in the framework of a research project in which I seek to analyse the functioning of this unprecedentedly broad and ambitious initiative of multi-stakeholder drafting of a code of practice on general-purpose AI, seeking to understand which civil society actors participated in this initiative and how they contributed to the drafting of this code.

I look forward to receiving your reply within 15 business days, as established by Regulation 1049/2001. My postal address is Via Bolognese 156, 50139 Firenze FI, Italy. However, I request this information in electronic form.

Many thanks for your work and best regards,
Mateus Carvalho

Dear DG CONNECT Access to Documents Team,

Many thanks for your reply and fair solution proposal of 10 February 2026. In it, you have kindly asked me to do two things: first, to “specify the objective of [my] request” and, secondly, to “narrow down the scope” of my request to 15 documents. I will deal with these two requests separately.

Firstly, regarding the requested specification of my request, I consider that I have already provided enough justification of the reasons of my request in my first message, of December 6th. In brief, I am requesting these documents in the framework of a research project where I am studying participatory initiatives at the EU level, including the process of multi-stakeholder drafting of the code of practice on general-purpose AI, seeking to understand which civil society actors participated in this initiative and how they contributed to the drafting of this code.

Moving on, and regarding the request to narrow down the scope of my request to 15 documents, I would first like to thank you for listing the types of documents you hold that may fall within the scope of my request.

However, I feel compelled to respectfully point out that the requested limitation of my request to 15 documents does not have any specific basis in EU secondary law or related case law. While I acknowledge and fully understand the need of the Commission to reduce the workload involved in processing and handling the request documents, I nonetheless would like to signal that reducing the request to 15 documents makes it excessively narrow for the purposes of my research. Meaningful research analysis relies on access to sufficient data, and the proposed limitation could impair the usefulness of this request for my research work. Moreover, if one consults repositories of access to information requests – such as the platform where this request itself is being handled – it is possible to see that there have been many past instances of fair solution proposals that have entailed the sharing of much more than 15 documents, both before and after the Commission started asking, as a reiterated practice in its fair solution proposals, for a narrowing down of requests to 15 documents.

In this sense, I would like to kindly ask for access to:

1. Documents stating the list of participating organisations, researchers and experts, approximate number: 7 documents
• List of participating organisations for the overall drafting: 1 document;
• List of all participants: 1 document;
• Minutes of workshops: 5 documents.
Note: If needed to reduce the number of documents to be sent, I would accept receiving just the minutes of workshops (5 documents).

2. Powerpoint presentation summarizing the applications and selection process shared with the Plenary, approximate number: 1 document;

3. Contributions to feedback forms of the drafting process of the GPAI code of practice, namely:
3.1. Feedback form 1st draft GPAI Code of Practice, approximate number: 354 documents;
3.2. General feedback form 2nd draft GPAI Code of Practice, approximate number: 229 documents;
3.3. Feedback form 2st draft GPAI Code of Practice Working Group 2, approximate number: 150 documents;
3.4. General feedback 3rd draft GPAI Code of Practice, approximate number: 158 documents;
3.5. Feedback form 3rd draft GPAI Code of Practice Working Group 2, approximate number: 107 documents.
Note: if needed to reduce this list of documents, please do reduce the documents of the general feedback forms (3.1., 3.2. and 3.4.) only to contributions that relate to the chapter on Safety and security (so not including transparency or copyright rules).

4. Reports on Inception, State of Play, Progress of the Chapters, Deliverables Status, Final Report, Contract, approximate number: 8 documents

5. Submissions GPAI consultation before the CoP drafting: of the existing 427 documents, please limit the disclosed documents only to contributions that mention questions of systemic risk identification, assessment and mitigation that relate to the CoP’s chapter on Safety and security (so not including transparency or copyright-related rules).

If necessary due to the global workload, please do take more than the deadline of 15 working days, just as was done to respond to my initial request, whose response was sent significantly after the legally prescribed deadline (the initial request was made on December 6th and the fair solution proposal was sent on February 10th, thereby totalling approximately 39 working days, if my calculations of public holidays are correct).

Many thanks for your work and kind regards,

Mateus Carvalho