Irish law on AI training data is EU law plus three national pieces: the reservation form in section 53B of the Copyright and Related Rights Act 2000, the enforcement powers of the Data Protection Act 2018, and the Data Protection Commission (DPC), which supervises many AI buyers through their Irish entities. S.I. No. 567 of 2021, signed on 2021-11-12, inserted section 53B, and the DPC has used sections 110 and 134 of the Data Protection Act 2018 against AI training between 2024-08-08 and 2025-04-11.
This page sets out the instruments, dated changes and seller-side programs as of 2026-11-09, for the data holder and for the AI developer. It is a free-to-read part of the wider reference on AI training data licensing, covers EU rules only where Ireland differs from or implements them, and cites the Irish Statute Book and the regulator's own statements. The DPC published its AI Insights Report on 2026-09-25, and Ireland's Article 77 authorities hold their powers from 2026-08-02.
Each figure is dated and checked against the official text, as described in the method for sourcing and dating every figure.
What Irish Law Adds to EU Rules Before a Company Licenses Data for Training
Irish law decides four things on top of the EU instruments: how a reservation against mining must be expressed, which enforcement routes the Irish regulator uses against training on personal data, who supervises the buyer, and how royalties to and from Ireland are taxed.
- Reservation form: Copyright and Related Rights Act 2000, section 53B(3).
- Enforcement: Data Protection Act 2018, sections 110 and 134.
- Supervision: the DPC as regulator of the buyers' Irish entities.
- Tax: the US treaty rate on royalties paid to Irish residents.
The GDPR (Regulation (EU) 2016/679, applies from 2018-05-25) applies directly in Ireland. Rules on workplace monitoring and on recording calls and meetings are not recorded on this page.
Irish Instruments and Regulator Actions That Apply to a Training Data Deal
Nine Irish instruments, regulator positions and record gaps shape a training-data license, and the table gives each citation, its date and whether it is final, pending or not stated. Rows with a page of their own link to it, and "not stated" means no primary source was verified on 2026-11-09, not that no rule exists.
| Instrument | Citation | Dates | What it decides in a data deal | Final, pending or not stated | Source |
|---|---|---|---|---|---|
| Copyright and Related Rights Act 2000, s.53B | S.I. No. 567 of 2021, reg. 4; CRRA 2000 s.53B | S.I. signed 2021-11-12; in force, commencement date not stated | commercial TDM exception; reservation must be machine-readable for online content, including metadata and website terms (s.53B(3)) | final | irishstatutebook.ie |
| Data Protection Act 2018 | No. 7 of 2018, s.110 and s.134 | in force | s.110 inquiries; s.134 urgent High Court applications on notice | final | irishstatutebook.ie |
| GDPR | Regulation (EU) 2016/679 | applies from 2018-05-25 | legal basis, notices and transfers for personal data in the set | final | eur-lex.europa.eu |
| AI Act national authorities (Art. 77) | Regulation (EU) 2024/1689, Art. 77, per the Department of Enterprise | powers apply from 2026-08-02 | Art. 77 powers of fundamental-rights authorities apply in Ireland; implementing legislation not stated | final (date) | enterprise.gov.ie |
| DPC AI Insights Report | Data Protection Commission report | published 2026-09-25 | regulator view that private messages are unlikely to be expected for AI training; about 180 AI products engaged 2021 to 2025 | regulator position, not law | dataprotection.ie |
| US-Ireland treaty rates on royalties | IRS Tax Treaty Table 1, Rev. May 2023, income codes 10 and 12 | as of 2026-11-09 | 0% US withholding for Irish residents, subject to limitation on benefits | final | irs.gov |
| Irish withholding on royalties paid abroad | not stated | not stated | not stated | not stated | n/a |
| Workplace monitoring | not stated | not stated | not stated | not stated | n/a |
| Recording of calls and meetings | not stated | not stated | not stated | not stated | n/a |
How Each Irish Rule Reaches the Seller and the Buyer
The table lists each instrument; the sections below show what each one asks of the data holder and of the AI developer.
Reserving Content Under Section 53B: Metadata and Website Terms
Section 53B of the Copyright and Related Rights Act 2000, inserted by S.I. No. 567 of 2021 (regulation 4, signed 2021-11-12), is Ireland's commercial text and data mining exception, and a rightholder takes content out of it with a reservation. Under section 53B(3) a reservation is appropriate where it is machine-readable for online content, "including metadata and terms and conditions of a website or a service", or clearly communicated for offline content. The commencement date of section 53B and any Irish provision for research mining are not stated on this page.
For a seller, website terms count as a reservation channel in Ireland, so a publisher's terms page plus metadata carries the reservation that makes a license the route to its content. The Directive's rule and the opt-out debate sit on the page about the EU text and data mining exception.
Personal Data in the Set: What the Data Protection Act 2018 Adds
The GDPR decides whether personal data in a dataset may be licensed for training, and the Data Protection Act 2018 (No. 7 of 2018) adds the Irish enforcement machinery: inquiries under section 110 and urgent High Court applications under section 134. Where the Commission considers there is an urgent need to act to protect data subjects' rights and freedoms, section 134 lets it apply on notice, in a summary manner, to the High Court for an order. Other provisions of the Act, such as those on research or further processing, are not stated here.
The DPC's AI Insights Report (September 2026) states that it is "unlikely that a controller will be able to demonstrate that data subjects expect the usage of their private messages or other private data for AI training". That is the Irish regulator's view, not a court holding, and the legal-basis analysis sits in GDPR and AI training data.
Irish Regulator Actions on Training Data, 2024 to 2026
The Data Protection Commission has used both Data Protection Act 2018 routes against AI training: a section 134 application against Twitter over Grok training on 2024-08-08, a section 110 inquiry into Google Ireland Limited's PaLM 2 model on 2024-09-12, and a section 110 inquiry into X Internet Unlimited Company's Grok training on 2025-04-11. The PaLM 2 inquiry concerns the duty under Article 35 GDPR to run a data protection impact assessment before processing EU and EEA personal data. On 2025-05-21 the DPC reported Meta's planned start of training on EU adults' public content on 2025-05-27, after measures including a legitimate interest assessment, a DPIA and a compatibility assessment, and the DPC does not confirm the actual start. The DPC counts about 180 AI products and services it engaged with from 2021 to 2025, which is its own count.
Why Many AI Buyers Contract Through Irish Entities
Several frontier buyers deal with EU users and sellers through Irish companies, which is why the Irish regulator leads their EU supervision and why Irish law reaches deals far beyond Irish holders.
- Meta Platforms Ireland Limited is Meta's EU entity, and section 1.2 of the WhatsApp Business Platform terms (last modified 2026-09-23) puts customers outside the US and Canada under a contract with it, checked 2026-11-09.
- Google Ireland Ltd is described in the CJEU press release of 2026-11-03 as the Alphabet group member providing Gemini.
- OpenAI Ireland Ltd is a defendant with OpenAI, L.L.C. in GEMA v OpenAI, Regional Court Munich I, 42 O 14139/24.
- LinkedIn Ireland Unlimited Company is the contracting party for members in the EU, EEA and Switzerland under section 1.1 of the User Agreement, checked 2026-11-09.
The Italian Garante sent its OpenAI file to the Irish DPC (announced 2024-12-20) after its decision no. 755 of 2024-11-02 (the Tribunale di Roma upheld OpenAI's opposition to it in judgment n. 4153/2026, published 2026-03-18), and the EDPB adopted Opinion 28/2024 on 2024-12-17 at the Irish authority's request. The buyers themselves are compared under frontier AI labs as data buyers.
Workplace Monitoring and Call Recordings: Not Yet Recorded for Ireland
No Irish rule on workplace monitoring or on recording calls and meetings is recorded on this page as of 2026-11-09, so internal messages and recordings are assessed under the GDPR alone here. The comparison pages in the last section hold the jurisdictions that are recorded.
Royalty Payments Between Ireland and the United States
A US buyer paying a royalty to an Irish-resident seller withholds 0% on copyright royalties (income code 12) and on other industrial royalties (income code 10) under IRS Table 1, Rev. May 2023, subject to the treaty's limitation-on-benefits test. Irish withholding on royalties paid by an Irish buyer to a non-resident is not stated here. Rates for other countries are compared on the withholding page for royalties.
Enacted, Pending and Proposed: Irish Changes as of November 2026
Nine dated items changed how Irish law and the Irish regulator treat training data, and the table keeps statutes, regulator actions and soft law apart.
| Date | Item | Citation or actor | Status as of 2026-11-09 | Source |
|---|---|---|---|---|
| 2026-09-25 | AI Insights Report published | Data Protection Commission | published; private-messages position; about 180 AI products engaged 2021 to 2025, DPC's own count | dataprotection.ie |
| 2026-08-02 | Art. 77 fundamental-rights authorities' powers apply in Ireland | Regulation (EU) 2024/1689, per the Department of Enterprise | applies | enterprise.gov.ie |
| 2025-05-21 | DPC statement on Meta AI | Data Protection Commission | Meta's planned EU training start 2025-05-27 as reported by the DPC; actual start not confirmed; effectiveness report expected October 2025 | dataprotection.ie |
| 2025-04-11 | Inquiry into X Internet Unlimited Company (Grok training) announced | DPA 2018 s.110 | announced | dataprotection.ie |
| 2024-12-20 | Garante announces sending its OpenAI file to the Irish DPC | Garante decision no. 755 of 2024-11-02 | announced | garanteprivacy.it |
| 2024-12-17 | EDPB Opinion 28/2024 adopted at the Irish authority's request | Art. 64(2) GDPR | adopted; soft law, not binding on courts | edpb.europa.eu |
| 2024-09-12 | Inquiry into Google Ireland Limited (PaLM 2 DPIA) announced | DPA 2018 s.110; Art. 35 GDPR | announced | dataprotection.ie |
| 2024-08-08 | Urgent High Court application against Twitter (Grok training) | DPA 2018 s.134 | made; outcome not stated | dataprotection.ie |
| 2021-11-12 | S.I. No. 567 of 2021 signed, inserting s.53B | European Union (Copyright and Related Rights in the Digital Single Market) Regulations 2021 | signed | irishstatutebook.ie |
Inquiries are not decisions, and an EDPB opinion does not bind courts. The national legislation implementing the AI Act, and any authority it creates, is not stated on this page. Whether Meta delivered the effectiveness report the DPC expected in October 2025 is not stated either. Court rulings on training data are tracked in the AI copyright lawsuits over training data tracker.
Programs That Accept EU Company Data From Irish Holders
Six programs state on their own pages that they accept company data from the EU or Europe, each as a claim checked 2026-11-09, none names Ireland, and none changes what Irish law requires of the seller.
| Program | Role | What it acquires or handles | What its own pages say about EU or European companies (checked 2026-11-09) | Source |
|---|---|---|---|---|
| Collinear AI, paid data licensing | buyer program | repositories with PRs and tickets, Slack, Gmail, Jira and similar company records | English data; US, CA, UK, EU, AU, NZ; teams of about 50+; several years of human-written history | collinear.ai |
| Handshake AI, Data Partnerships | buyer program | workflow and documentation data | estimator country input: USA, Canada, Europe, Other | joinhandshake.com |
| Mode, data partnership program | buyer program | email, documents, chat, calls and transcripts | agreement names US, EU, Canada, Australia; home page calls the US the strongest fit | data.mode.inc |
| Nyne, data partnerships | buyer program | operational workflow data | country selector offers Europe, yet requires 20+ full-time U.S. W-2 employees | nyne.ai |
| Ooak Data, data partner program | buyer program | Slack, Gmail, Notion, Jira and similar records | EU partner data processed and stored in the EU via Ooak Data SAS; company must own its records | ooakdata.com |
| Turing, Project Lazarus | buyer program | records of active and shut-down companies | most regions; strongest demand US, UK, Canada, EU | lazarus.turing.com |
Two contradictions stay visible: Mode's agreement names the EU while its home page calls the US the strongest fit, and Nyne offers Europe in its selector but asks for 20+ U.S. W-2 employees. One Irish-content deal exists outside these programs: Google's 2026-10-12 agreement with Reach plc covers enhanced content rights across Reach's UK and Ireland portfolio, with the value not disclosed, per Reach's statement. Terms across all programs are compared in the company data partnership programs page.
Benefits, Risks, Downsides and Alternatives of Licensing Data Under Irish Law, Including Not Selling
Irish law lets a company license data it holds the rights to, and the section 53B reservation gives online content license value, but the GDPR, an active regulator and unrecorded national items add conditions, and not licensing remains a valid choice.
Benefits
- Website terms and metadata count as a reservation under section 53B(3).
- A 0% US treaty rate applies to royalties paid to Irish residents, subject to limitation on benefits.
- The regulator's published positions show what it expects.
Risks
- The section 134 route allows an urgent High Court application on notice.
- Section 110 inquiries have reached Google and X Internet Unlimited Company.
- Private messages are unlikely to meet data subjects' expectations, per the DPC.
Downsides
- The assessments the DPC looks for (legitimate interest, DPIA, compatibility) cost time before any income.
- Unrecorded national items on withholding, monitoring and recording mean advice per deal.
Alternatives
- License only content without personal data.
- Keep the data and record a section 53B reservation.
- License de-identified data.
- Not selling or licensing at all, among the alternatives to selling data to AI labs.
Beyond the Irish Layer: EU Instruments, Topic Comparisons and the Sale
Irish law stops at the EU layer above it and at the contract; the pages below cover the EU instruments, compare topics across jurisdictions and apply the rules to a sale.
- European Union rules for AI training data, the parent and the EU layer above Irish law.
- AI training data law by jurisdiction, every jurisdiction compared.
- EU AI Act Article 53, what the AI Act asks of model providers.
- EU Data Act and AI training data, access and contract terms.
- copyright and AI training across jurisdictions, how copyright exceptions compare.
- employee data and AI training rules by jurisdiction.
- call and meeting recording consent rules compared.
- robots.txt for AI crawlers, machine-readable signals.
- selling data to AI companies from outside the US.
- sell or license company data to AI companies, the steps of a sale.
- United Kingdom rules for licensing data, the neighbor next door.
- privacy law and AI training data compared across jurisdictions.
How This Page Is Sourced and Dated
Every rule here cites the Irish Statute Book, the Data Protection Commission's own statements, the Department of Enterprise's AI Act page or the IRS treaty table, with the date it was checked. The rules for dating and checking are set out in the method for sourcing and dating every figure. This page is general information about Irish law, not legal advice for any specific deal.
Frequently Asked Questions
How does a rightholder in Ireland reserve online content from AI mining?
By a reservation that is machine-readable for online content. Section 53B(3) of the Copyright and Related Rights Act 2000 counts metadata and the terms and conditions of a website or a service.
Which Irish law lets the DPC act against AI training?
The Data Protection Act 2018. Section 110 provides for inquiries and section 134 for urgent High Court applications on notice.
When did Meta plan to start training on EU users' public posts?
On 2025-05-27, as reported by the DPC on 2025-05-21. The DPC does not confirm the actual start.
Does Ireland have its own employee-monitoring rule for AI training data?
None is recorded on this page as of 2026-11-09. The GDPR applies to employee data in the set.