Can a regulator force deletion of an entire AI model?
Quick Answer
Theoretically, yes. EDPB Opinion 28/2024 states possible measures include erasure of the whole dataset used to develop the AI model and/or the AI model itself. In practice, regulators would first consider fines and corrective measures. No regulator has ordered model deletion yet.
Detailed Answer
Theoretically, yes. The EDPB Opinion 28/2024 states that possible remediation measures include erasing part of the dataset that was processed unlawfully or, where this is not possible, the erasure of the whole dataset used to develop the AI model and/or the AI model itself.
In practice: This would need to be proportionate. Regulators would likely first consider:
- Output filtering (preventing specific data from appearing)
- Retraining on a cleaned dataset
- Fines and corrective measures
- Model deletion as a last resort
No regulator has ordered model deletion yet, but the legal basis exists.


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