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General-purpose AI model obligations: thresholds and duties for providers

The AI Act imposes specific obligations on providers of general-purpose AI models, with stricter duties for models with systemic risk. The Commission guidelines of July 2025 give compute-based criteria to tell which models and which providers are concerned.

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Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

Which models are concerned

The Commission uses training compute and modality as an indicative criterion: a model is considered general-purpose if its training compute exceeds 10^23 FLOP and it can generate language (text or audio), text-to-image or text-to-video. The guidelines acknowledge that compute is an imperfect proxy for generality.

Under Article 51(2), a model trained with more than 10^25 FLOP of cumulative compute is presumed to have high-impact capabilities and therefore systemic risk. Providers must notify the Commission without delay and in any event within two weeks after the threshold is met or it becomes known that it will be met.

A downstream modifier becomes the provider of the modified model only if the modification significantly changes its generality, capabilities or systemic risk. The indicative criterion is that the compute used for the modification exceeds a third of the original model's training compute.

What providers must do

All providers must draw up and keep up to date technical documentation for downstream providers and, on request, for the AI Office and national authorities. They must also put in place a policy to comply with Union copyright law and publish a summary of the content used for training.

Providers of models released under a free and open-source licence, with weights, architecture and usage information publicly available, are exempt from some of these documentation duties, unless the model has systemic risk.

Providers of models with systemic risk must additionally assess and mitigate those risks. The Service Desk FAQ notes that most of the relevant providers have signed and are implementing the GPAI Code of Practice for this purpose.

Frequently asked questions

From when do the general-purpose AI model rules apply?

Chapter V applies from 2 August 2025. Providers of models placed on the market before that date must comply by 2 August 2027. The Commission's enforcement powers over these providers enter into application on 2 August 2026.

What can the Commission do if a model provider does not comply?

According to the Service Desk FAQ, it can request information, request access to a model for evaluations, require risk mitigation measures, issue fines of up to 3 % of global annual turnover, or ask the provider to restrict, withdraw or recall the model. The AI Office treats technical compliance dialogues as its first tool.

Can a downstream provider complain about a model provider?

Yes. Downstream providers building an AI system on a general-purpose AI model may lodge a complaint with the Commission if they consider that the model provider infringed Articles 53 to 55. Complaints are handled confidentially, but they do not automatically lead to proceedings.

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