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General-purpose AI models.

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Short answer

Since 2 August 2025, providers of general-purpose AI models must keep technical documentation, give information to providers that build on the model, have a policy to respect EU copyright law including text-and-data-mining opt-outs, and publish a summary of the training content (Article 53); models with systemic risk, presumed above 10^25 floating-point operations of training compute, must also be evaluated, have their systemic risks assessed and mitigated, report serious incidents and be kept secure (Article 55). Models placed on the market before 2 August 2025 have until 2 August 2027, and the Commission can fine providers from 2 August 2026.

Official sources: AI Act, Article 53 · Article 55

The obligations

Obligations of providers of general-purpose AI models
ObligationAll GPAI modelsOpen-source modelsSystemic-risk modelsArticle
Technical documentation for the AI Office and national authorities (Annex XI)YesNoYes53(1)(a)
Information and documentation for downstream providers (Annex XII)YesNoYes53(1)(b)
Policy to comply with EU copyright law, including machine-readable opt-outs (Directive 2019/790, Article 4(3))YesYesYes53(1)(c)
Public summary of training content, on the AI Office templateYesYesYes53(1)(d)
Authorised representative in the EU, if established outside itYesNoYes54
Model evaluation incl. adversarial testing; assessing and mitigating systemic risks; incident reporting; cybersecurity——Yes55(1)

“Open-source” here means released under a free and open-source licence that allows access, use, modification and distribution, with the weights and architecture published (Article 53(2)). The exemption does not apply to models with systemic risk.

Is it a general-purpose AI model?

  • Commission guidelines give an indicative criterion: training compute above 10^23 floating-point operations and the ability to generate language (text or audio), text-to-image or text-to-video.
  • A model is presumed to have high-impact capabilities, and so systemic risk, when its cumulative training compute exceeds 10^25 floating-point operations (Article 51(2)); the Commission can also designate a model (Article 51(1)(b)).
  • A provider whose model meets the compute threshold, or will, must notify the Commission without delay and within two weeks at the latest, according to the Commission’s guidelines Q&A.
  • Modifying someone else’s model does not automatically make you its provider: the guidelines’ threshold for modifications “means most fine-tuning, adaptations, and minor modifications will not subject developers to the obligations for providers”.

The General-Purpose AI Code of Practice

Published on 10 July 2025, the code has three chapters: Transparency and Copyright, which give every provider a way to show compliance with Article 53, and Safety and Security, which matters only for the few providers of systemic-risk models under Article 55. The Commission and the AI Board confirmed it as an adequate voluntary tool; providers sign by sending the signatory form to the AI Office (Commission page).

Supervision and fines

The AI Office supervises general-purpose AI models. The Commission may fine their providers up to 3 % of annual total worldwide turnover or EUR 15 000 000, whichever is higher, for intentional or negligent infringements or for failing to answer information requests (Article 101); that article applies from 2 August 2026.

The general-purpose AI rules concern the model. Marking the outputs of AI systems is a separate duty under Article 50(2), with its own Code of Practice on AI-generated content.

Questions

Do the GPAI obligations apply to open-source models?
Partly. Providers of open-source models with published weights are exempt from the documentation duties in Article 53(1)(a) and (b), but they still need a copyright policy and a public training-content summary. Models with systemic risk get no exemption.
When must models released before August 2025 comply?
By 2 August 2027. Article 111(3) gives providers of general-purpose AI models placed on the market before 2 August 2025 until that date to take the necessary steps.

Sources

Last reviewed by Volkan Çatak, Founder, Proofcan.

Not legal advice. This page explains official texts in plain words and links each one; check the sources, or a lawyer, before relying on it for a decision.