On August 2, 2025, the European Union’s AI Act ushered in binding obligations for general-purpose AI (GPAI) models—marking a significant milestone in global AI regulation. These rules confront the pressing challenges of transparency, copyright, systemic risk, and accountability, setting out a robust compliance framework for developers, vendors, and users of advanced AI technologies.
What Is a General-Purpose AI Model?
General-purpose AI (GPAI) models are powerful machine learning systems—like large language models or general foundation models—that:
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Are trained on massive datasets (typically exceeding 10²³ FLOPs)
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Display broad generality and can perform a wide variety of tasks
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Are capable of integration into diverse downstream systems and applications
GPAI models with systemic risk—those with even higher compute (10²⁵ FLOPs or more) or significant impact on society—face enhanced regulatory scrutiny.
The Core EU GPAI Obligations
1. Transparency
Providers must:
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Maintain and publish detailed technical documentation about model architecture, training processes, capabilities, and limitations
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Make available a summary of training data using the official EU template, enabling both authorities and users to understand the data sources and scope
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Clearly convey the AI model’s intended and permitted uses
2. Copyright Compliance
Providers are required to:
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Implement effective policies to respect European copyright and database rights
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Identify and honor rights reservations in training and output data
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Address copyright complaints efficiently, designating a point of contact for such matters
3. Systemic Risk Mitigation (For High-Impact Models)
Models that meet the systemic risk threshold must:
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Perform regular risk and safety assessments and adopt mitigation frameworks
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Report serious incidents to the AI Office and relevant authorities
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Implement cybersecurity best practices to prevent manipulation or misuse of the AI
4. Clear Definitions and Lifecycle Obligations
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The model’s lifecycle—the period spanning initial training, deployment, and all subsequent modifications—determines regulatory responsibilities and when compliance is triggered
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The “provider” is generally the party who develops and places the model on the EU market; modifications downstream can shift this role with significant customization or retraining
Compliance Tools: Guidelines, Code of Practice & Documentation Template
To smooth the path for providers, the European Commission offers:
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Detailed Guidelines: Non-binding, but authoritative guidance on model classification, compliance obligations, and enforcement
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General-Purpose AI Code of Practice: A voluntary but Commission-approved tool outlining best practices for transparency, copyright, and risk management. Adopted signatories benefit from reduced administrative burden and enhanced legal certainty
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Training Data Summary Template: A standardized format to describe training datasets, required for all GPAI documentation
The New Compliance Landscape
Organizations that develop, sell, or use GPAI models in the EU must:
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Establish dedicated compliance programs tailored to the AI Act’s rules
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Integrate transparency and documentation into every phase of the AI lifecycle
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Track actual and estimated model training compute to determine if the GPAI or systemic risk thresholds are met
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Respond promptly to regulatory inquiries and potential copyright issues
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Anticipate ongoing oversight, future amendments, and escalation of obligations as the AI market and regulatory environment evolve
This paradigm shift is driving new demand for expertise in:
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AI governance and regulatory affairs
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Risk management focused on model safety and AI ethics
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Copyright and intellectual property law in the context of AI
How to Demonstrate Compliance
Providers can:
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Sign up for the Code of Practice to voluntarily commit to the EU’s standards (recommended for streamlined compliance)
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Alternatively, develop bespoke compliance solutions—but these must meet or exceed the standards set out in EU guidelines
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For models developed before August 2, 2025, there is a two-year grace period for compliance (until August 2, 2027)
The EU’s approach is already influencing regulatory debates in the U.S., UK, and beyond, setting a high bar for responsible AI. By enshrining transparency, accountability, and risk mitigation at the heart of AI lifecycle, the EU AI Act seeks to balance innovation with fundamental rights, fostering trust among users, businesses, and regulators worldwide.
The EU AI Act represents a watershed moment for AI governance, requiring a proactive, lifecycle-based approach to compliance. Organizations should act now to adapt to this new standard, leveraging available guidelines and tools to ensure ethical, lawful, and accountable AI in Europe and beyond.
Frequently Asked Questions (FAQ)
Q1: What are the key criteria for classifying GPAI models?
A: Models trained with over 10²³ FLOPs and capable of a wide range of tasks, especially those generating language, are classified as GPAI; higher-capacity models (over 10²⁵ FLOPs) may be deemed systemic risk models.
Q2: If I use a GPAI model from another provider, am I a provider under the AI Act?
A: It depends. Integrating an unmodified GPAI into your product doesn’t make you a provider, but significant modifications—like retraining—can shift that responsibility to you.
Q3: Do open-source GPAI models fall under these rules?
A: Open-source GPAI models may still be subject to the obligations, though certain exceptions exist, particularly for models not placed on the market or under active development.
Q4: Is signing the Code of Practice mandatory?
A: No, it’s voluntary, but doing so greatly improves legal certainty and streamlines the compliance process. Providers may alternatively use other mechanisms to evidence compliance.
Q5: How is training data compliance checked?
A: Providers must use the EU’s official template to publish summaries of model training data. Authorities may request further detail or conduct audits for verification.
Q6: What is the timeline for compliance?
A: For new GPAI models, obligations began on August 2, 2025. Existing models on the market before this date have until August 2, 2027, to demonstrate compliance.
Q7: What happens if I fail to comply?
A: Non-compliance can lead to enforcement actions, including fines, orders to withdraw models from the EU market, or other regulatory penalties as detailed in the AI Act.