EU AI Act Obligations for General-Purpose AI Models Now Apply

Ahead of the deadline, on 18 July 2025 the European Commission published guidelines explaining the scope of the obligations. The guidelines treat a model as general-purpose where it was trained using more than 10²³ floating point operations and can generate language, text-to-image or text-to-video output. They also clarify who counts as a provider, what amounts to placing a model on the market and how the exemptions for free and open-source models work.

What providers must do

Under Article 53, providers must draw up and keep up to date technical documentation for the model, make information available to downstream providers that integrate the model into their own systems, put in place a policy to comply with EU copyright law and publish a sufficiently detailed summary of the content used for training. Providers of models with systemic risk face additional duties under Article 55, including model evaluation, assessment and mitigation of systemic risks, serious incident reporting and adequate cybersecurity protection.

The General-Purpose AI Code of Practice, published by the Commission in July, offers a voluntary way of demonstrating compliance with these obligations, and the guidelines explain what adhering to it implies.

Enforcement timetable

The obligations apply now, but the Commission's powers to enforce them, including fines on providers of general-purpose AI models, apply from 2 August 2026. Providers of models placed on the market before 2 August 2025 have until 2 August 2027 to comply. Other parts of the regulation, including the governance framework and the rules on penalties to be laid down by Member States, also began to apply on 2 August 2025.

Who is affected

Developers of foundation models, companies that fine-tune or modify such models significantly, and businesses building products on top of third-party models should review which obligations apply to them and what information they can expect to receive from upstream providers.

Sources

• European Commission: Commission publishes guidelines for providers of general-purpose AI models
• EUR-Lex: Regulation (EU) 2024/1689 (Artificial Intelligence Act)