MACHINE ACCESS / GOVERNED CONTINUATION
01 Institutional letter ENTIA is presenting an implementation, not asking the Commission to adjudicate a commercial dispute.
OPENING POSITION
A maintained European economic identity corpus is already being accessed systematically by machine systems. ENTIA has measured that access and is establishing the legal and economic conditions for its continuation.
To: Directorate-General for Communications Networks, Content and Technology (DG CONNECT) and the European AI Office
ENTIA submits this briefing to present an operational European implementation built around a simple fact: a maintained economic identity corpus is already being accessed systematically by automated systems, including declared crawler families associated with search, AI and answer engines, and data-intelligence providers.
ENTIA has measured that access, implemented machine-readable reservations of rights for text and data mining, preserved policy versions and access evidence, and begun establishing a legal and economic framework under which continued machine access can be licensed.
The legal position is deliberately layered. It relies on machine-readable TDM reservations for qualifying protected subject matter; the sui generis database right where the required investment and extraction or re-utilisation conditions are established; rights in software, structure, documentation, identifiers, verification and presentation; and contractual licensing activated through a valid acceptance or payment mechanism.
ENTIA does not ask the European Commission to determine that any individual operator has infringed rights, to impose payment, or to endorse a bilateral commercial claim. We ask the Commission services to review the implementation as a case study, identify an appropriate technical contact point, include ENTIA in relevant policy and interoperability work, and accompany the development of a practical European model connecting rights expression, corpus identity, access evidence and authorised continuation.
What ENTIA is presenting What ENTIA is not asking the Commission • A deployed corpus and publication infrastructure. to do • Machine-readable TDM reservations and preserved • Determine infringement by a named operator. policy versions. • Impose remuneration or endorse a bilateral commercial • Documented machine-access telemetry and evidence claim. architecture. • Infer training, RAG, grounding or another undisclosed • A practical route from observed access to licensed downstream purpose. continuation. • Condition ENTIA’s licensing framework on an EU pilot.
Fernando Vilches Founder, ENTIA PrecisionAI Marketing OÜ Tallinn, Estonia
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02 Executive proposition The framework is designed around an existing access relationship, not a new integration project.
CORE PROPOSITION
ENTIA is not asking operators to explain which product uses the corpus, whether the access supports search, indexing, grounding, RAG, training, evaluation or another internal function. ENTIA is establishing the conditions under which the access already taking place may continue.
11.33M 1.345M 30 26.0 GB ECONOMIC IDENTITIES EXTERNAL REQUESTS DECLARED UA FAMILIES ORIGIN EGRESS
OPERATIONAL MODEL
Operational fact ENTIA response
11.33 million resolved economic identities 1 A maintained corpus exists published for machine and human use.
1.345 million external machine requests 2 Machine access is observable recorded in the current forensic window.
Machine-readable TDM reservations, 3 Rights are expressed versioned policies and human-readable terms are published.
Per-request telemetry, analytical records, 4 Evidence is preserved hashes and timestamping capability support reproducibility.
An active licence can govern continued access without requiring disclosure of 5 Continuation is governed downstream use or a new technical integration.
What ENTIA asks from an accessing What ENTIA does not require operator • Disclosure of the product, model, workflow, team or internal integration using the corpus. • Acknowledge the published legal and economic framework. • A declaration that access is for training, search, grounding, evaluation or any other specific purpose. • Activate the applicable licence through a valid contractual mechanism. • Migration to a new API, feed or credentialled route as a prerequisite to licensing the existing access. • Comply with the licence conditions while automated access continues. • Admission of infringement or acceptance of ENTIA's interpretation of downstream use.
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03 The object being accessed The unit of value is the resolved economic identity, not the page view.
ENTIA has built an economic identity infrastructure that resolves organisations and economic actors into persistent, machine-readable objects. The public profile currently covers 11,330,392 economic identities across ten countries.
Why the object has independent economic value ENTIA does not claim exclusive rights over every individual public fact. Its value arises from the infrastructure and investment required to obtain, verify, reconcile, structure, maintain and present economic identities as stable machine- readable objects.
Generic page or copied listing ENTIA Home
May describe a brand, product or marketing claim. Represents a specific legal or economic identity.
May be stale, duplicated or ambiguous. Is resolved, maintained and jurisdiction-aware.
Usually lacks field-level provenance. Connects the object to source-reference layers.
Primarily designed for human browsing. Delivered in HTML, JSON-LD and Markdown.
No systematic access evidence. Observed through per-request telemetry.
No explicit machine-access framework. Published with rights, policy and licensing signals.
OBJECTIVE DELIVERY
Machine systems are not merely viewing a web page. They are retrieving the output of an identity-resolution, verification, publication and governance process.
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04 Anatomy of an ENTIA Home A Home combines source facts, ENTIA processing and governed publication in one canonical economic identity object.
A machine request does not retrieve a loose collection of public facts. It retrieves a maintained object in which identity, provenance, verification, enrichment, publication and access governance are assembled around a stable ENTIA identifier.
TYPICAL CONTENT AND LEGAL-ECONOMIC CHARACTER
Layer Typical content What ENTIA contributes
Canonical mapping and disambiguation Legal name, aliases, jurisdiction, identifiers, Identity core between brands, branches, establishments and entity type, status, dates and address. legal persons.
Original values, source references, Assertion-level provenance and separation of Source assertions observation/effective dates and source- source fact from ENTIA-generated layers. specific terms.
Cross-source confirmations, contradictions, Ongoing verification, reconciliation and Verification state freshness, confidence and correction state. maintenance rather than static republication.
Harmonised sectors, territorial context, Derived context produced through ENTIA Enrichment relationships and contextual quality signals. taxonomies, resolution logic and infrastructure.
ENTIA ID, canonical route, HTML, JSON-LD, A stable, observable and contract-ready Publication + governance Markdown, rights signals, policy and telemetry. machine surface.
THE OBJECT OF VALUE
The economically relevant unit is not an isolated fact or a page impression. It is the resolved, verified, enriched, maintained and governed identity object delivered by ENTIA.
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05 Data lineage, enrichment and governance ENTIA preserves where a value came from, what changed, why it changed and which layer may be licensed.
The governance model is designed so that original source assertions, ENTIA transformations and derived contextual layers remain distinguishable throughout the lifecycle of the Home.
What ENTIA adds What ENTIA preserves • Normalised formats, identifiers, names, addresses, dates • The original source value and the source reference from and sector taxonomies. which it was obtained. • Canonical resolution, jurisdiction mapping, deduplication • Capture date, effective date, transformation history and and relationship modelling. version sequence. • Cross-source verification, contradiction state, freshness • Source-specific rights, attribution duties and and confidence-qualified assertions. redistribution or sublicensing constraints. • Territorial, sectoral and relational context plus ENTIA- • Correction, dispute and supersession history rather than generated quality signals. silent overwriting.
WHY GOVERNANCE INCREASES VALUE
Governance does not dilute the source data. It is the value-producing layer that makes the corpus resolvable, reproducible, maintainable, legally separable and usable at machine scale.
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06 Observed machine access Telemetry establishes systematic access and measurable delivery; it does not infer undisclosed downstream use.
7-27 Jul 19/21 0.9% 163,435 OBSERVATION WINDOW CAPTURED DAYS CACHE HIT 4XX RESPONSES
Figure 1. Request volume by declared functional crawler class. Categories describe observed User-Agent families and do not establish downstream use.
How the baseline should be read • The activity is distributed across several declared crawler classes; it is not dependent on a single operator or a single-day spike. • The names shown are declared User-Agent families. Operator-level attribution is maintained as a separate, confidence- qualified evidentiary question. • The licensing proposition does not depend on proving a hidden downstream purpose. Its factual starting point is repeated access to a maintained corpus.
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07 Declared agent landscape The names shown are declared User-Agent families. Attribution and downstream purpose remain separate evidentiary questions.
Figure 2. Leading declared User-Agent families in the 7-27 July 2026 baseline.
The pattern is persistent across search, AI and answer engines, SEO and data-intelligence systems, and other machine actors. The figures show that the corpus is being repeatedly requested and delivered at scale. They do not, by themselves, prove training, retention, RAG, product integration, infringement or economic damage.
ATTRIBUTION DISCIPLINE
ENTIA reports what the client declared, what network and route evidence supports, and the confidence of any operator mapping. It does not convert a User-Agent label into an unsupported allegation about a company, model or product.
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08 Legal architecture ENTIA separates TDM reservations, database protection, rights in its own layers and contractual continuation.
Layer Legal anchor ENTIA position
ENTIA publishes machine-readable reservation signals, versioned policies and human- TDM reservation Article 4(3), Directive (EU) 2019/790 readable terms. The current policy version is documented as effective from 19 July 2026. The reservation is not presented as retroactive.
Applicable where substantial qualitative or quantitative investment in obtaining, verifying or presenting contents is demonstrated and the Sui generis database right Article 7, Directive 96/9/EC relevant extraction or re-utilisation conditions are met, including repeated and systematic conduct under Article 7(5).
Software, schemas, taxonomies, original documentation, identifiers, verification signals, Copyright, software, documentation and ENTIA-owned layers enrichments, telemetry, manifests and contractual rights presentation layers are assessed separately from individual source facts.
National registers, open data, licensed Source-specific licences and public-sector providers and other anchors are not treated as Source rights terms interchangeable. ENTIA licenses only the layers and uses it is entitled to license.
The licence governs continued access after Order form, checkout, clickwrap or other valid Contractual continuation valid acceptance or payment. A request alone activation is not treated as contractual acceptance.
GPAI providers must maintain a policy to comply with Union copyright law. ENTIA AI Act relevance Article 53, Regulation (EU) 2024/1689 provides discoverable rights signals and evidence infrastructure; the AI Act does not itself create a private payment entitlement.
INSTITUTIONAL PRECISION
ENTIA is presenting a layered and evidence-conditioned legal position. It does not assert that every public fact is owned by ENTIA, that every request infringes a right, or that the existence of telemetry alone creates an automatic payment obligation.
The legal proposition is cumulative, not monolithic • TDM reservations express conditions for qualifying protected subject matter and are documented from their effective date. • The sui generis database-right position depends on demonstrable qualifying investment and the relevant extraction or re- utilisation analysis. • ENTIA-owned software, schemas, identifiers, verification signals, enrichments and evidence artefacts are analysed separately from source facts. • A commercial licence becomes binding through a valid activation mechanism - not merely because a request was observed.
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09 Governed continuation model The licensing proposition is intentionally simple.
No purpose disclosure is required for the standard route ENTIA does not condition licensing on an explanation of whether the corpus is used for search, indexing, user retrieval, grounding, RAG, training, fine-tuning, evaluation, deduplication or any other internal function. Those distinctions remain relevant to legal analysis and evidence, but they are not prerequisites for the standard continuation licence.
No new integration is required The commercial proposition is not the sale of a replacement crawler integration. Subject to the applicable licence and technical safeguards, the access mode already used by the operator may remain unchanged.
Optional service layers Authenticated APIs, managed feeds, delta delivery, provenance packages, rate arrangements, audit support and other technical services may be offered separately. They are enhancements, not conditions for licensing the access already occurring.
THE COMMERCIAL SENTENCE
The corpus may continue to be consumed in the same manner, but within an active economic licence.
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10 Evidence, integrity and limits ENTIA preserves facts and qualifications without converting telemetry into unsupported allegations.
Evidence supports Evidence does not establish by itself
Specified HTTP requests reached ENTIA-controlled Pretraining, training, fine-tuning or model evaluation. infrastructure at recorded times.
Clients declared specified User-Agent strings and requested Retention, internal storage, memorisation or embeddings. specified routes.
Response classes and measurable transfer were recorded RAG, grounding or use in a particular answer. where available.
Activity was repeated, persistent and concentrated across Integration into a particular product or downstream commercial functional classes. exploitation.
Policy versions, telemetry and aggregate analysis can be Infringement, contractual acceptance, damage or a universal preserved and reproduced. obligation to pay.
WHY THESE LIMITS STRENGTHEN THE SUBMISSION
ENTIA does not need to infer downstream purpose to present the operational problem. The documented fact is that machine systems repeatedly access a maintained corpus after discoverable rights and policy signals have been published.
Integrity design Validation gate before formal submission
• Edge request capture and preserved analytical records in • Complete the final read-only R2 reconciliation and explain R2/Parquet. any discrepancies. • Read-only analytical reconciliation using reproducible • Attach the exact machine-readable register of the 30 queries and documented exclusions. declared User-Agent families. • SHA-256 manifests and RFC-3161 timestamping capability • Complete the source-rights and database-investment for selected artefacts. evidence review. • Versioned policies, robots controls, headers, metadata and • Obtain external IP, database-right and TDM legal review. human-readable terms. • Exclude any metric that lacks a documented source, scope • Separate treatment of declared identity, network evidence, or reproducible basis. behavioural evidence and attribution confidence.
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11European relevance and institutional request ENTIA offers a concrete implementation that can inform the emerging European copyright infrastructure for AI.
European policy is increasingly focused on whether TDM reservations can be expressed in machine-readable form, connected to identifiable works or corpora, detected by AI developers and preserved as evidence. The European Commission's 13 July 2026 feasibility study concluded that an EU-level opt-out registry could be a useful complementary instrument and should complement, rather than replace, existing opt-out solutions and identifiers.
What ENTIA contributes as a case study • A defined, maintained corpus composed of stable economic identity objects. • Machine-readable publication surfaces and corpus identifiers. • Versioned TDM reservations, policy references and historical preservation. • Observed machine access measured without alleging undisclosed downstream use. • Evidence manifests capable of linking a policy version, corpus identity and access window. • A contractual route for continued access rather than treating blocking as the only response.
ENTIA asks the Commission services to
1 Designate a technical contact point Identify the appropriate channel within DG CONNECT and/or the European AI Office for review of the implementation.
2 Review ENTIA as a case study Assess the operational model connecting rights expression, corpus identity, evidence preservation and licensed continuation.
3 Include ENTIA in relevant work Consider ENTIA for consultations, workshops and stakeholder exchanges on machine-readable TDM reservations and AI copyright infrastructure.
4 Coordinate with related initiatives Indicate appropriate coordination points with EUIPO copyright-infrastructure work and any next steps following the 2026 registry feasibility study.
5 Explore an optional interoperability workstream If useful, test identifiers, policy versioning and evidence manifests in a narrowly scoped technical exercise that remains separate from ENTIA's commercial licensing framework.
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12 Essential annex Evidence snapshot, submission boundaries and official reference materials.
A. Current evidence snapshot Metric Current value Qualification
21 natural days; 19 compacted days; 11-12 Observation window 7-27 July 2026 UTC July are documented capture gaps.
Cloudflare machine-access telemetry External machine requests 1,345,324 aggregate; internal and human activity excluded.
Exact variants and attribution evidence are Declared User-Agent families 30 retained separately.
Response bytes, edge delivery and origin Origin egress 26.0 GB egress are treated as distinct measures.
Most measured traffic reached origin in the Cache HIT 0.9% current baseline.
Errors are separated from successful 4xx responses 163,435 (12%) retrieval.
Public profile across ten countries; rights Corpus profile 11,330,392 identities depend on layer and source.
B. Submission boundaries • This document is an institutional case-study submission, not a legal opinion or an allegation against a named operator. • The existence of a request does not by itself establish training, infringement, contractual acceptance or damage. • The TDM reservation is presented with its documented effective date and is not applied retroactively. • The sui generis database-right position remains dependent on evidence of qualifying investment and the applicable extraction or re-utilisation analysis. • Source rights and licence conditions remain subject to source-by-source review. • Commercial licences become binding only through a valid activation or acceptance mechanism.
SUBMISSION STATUS
This dossier is ready for institutional review as a structured case study. Formal submission should follow completion of the final read-only R2 reconciliation and external legal review.
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13 Official references and contact Core European materials, ENTIA public resources and institutional contact details.
01 Directive (EU) 2019/790 - Article 4, text and data mining https://eur-lex.europa.eu/eli/dir/2019/790/oj
02 Directive 96/9/EC - Article 7, sui generis database right https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31996L0009
03 Regulation (EU) 2024/1689 - Article 53, obligations for GPAI providers https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1689
04 European Commission feasibility study on an EU-level TDM opt-out registry - 13 July 2026 https://digital-strategy.ec.europa.eu/en/library/new-feasibility-study-introducing-eu-level-registry-text-and-data- mining-opt-out
05 ENTIA public telemetry https://entia.systems/telemetry
06 ENTIA licensing framework https://entia.systems/licensing
CONTACT
Fernando Vilches, Founder - ENTIA PrecisionAI Marketing OÜ | Tallinn, Estonia fv@entia.systems | entia.systems
Institutional review draft. Quantitative values reflect the documented Cloudflare baseline for 7-27 July 2026. Final read-only R2 reconciliation and external legal review remain validation gates before formal submission.