The Commission has issued guidelines to clarify the scope of the obligations for providers of general-purpose AI models under the AI Act. These obligations enter into application on 2 August 2025.
The guidelines on the scope of obligations for providers of general-purpose AI (GPAI) models help actors in the AI ecosystem understand whether the obligations apply to them and what is expected of them, ensuring they can innovate with confidence.
Key points of the guidelines
- Clear definitions: The guidelines introduce straightforward technical criteria, for instance for when an AI model is considered "general-purpose." This helps developers understand if they need to comply with the obligations under the AI Act.
- Pragmatic approach: The guidelines are designed to be pragmatic. For instance, they clarify that only those making significant modifications to AI models need to comply with the obligations for providers of GPAI models, not those making minor changes.
- Exemptions for open-source: The guidelines also clarify under what conditions providers of open-source AI models are exempt from certain obligations, to promote transparency and innovation.
Why are these guidelines important?
The guidelines explain how the Commission interprets key terms in the AI Act. This helps actors in the AI ecosystem understand who is expected to follow which obligations. Thus, the guidelines complement the General-Purpose AI Code of Practice, a voluntary, practical tool that explains how providers of GPAI models can fulfil their obligations under the AI Act.
Application and enforcement timeline
- From 2 August 2025, the obligations for providers of GPAI models enter into application. Providers of GPAI models placed on the market after this date must comply and are expected to informally collaborate with the AI Office’s technical staff. In particular, providers of the most advanced models, i.e. those that pose systemic risks, are legally obliged to notify the AI Office of these models. The AI Office will support providers in their compliance, especially Code of Practice signatories.
- From 2 August 2026, the Commission’s enforcement powers enter into application. The Commission will enforce compliance with the obligations for providers of GPAI models, including with fines.
- By 2 August 2027, providers of GPAI models placed on the market before 2 August 2025 must comply.
Developed through extensive public consultation with diverse stakeholders, these guidelines, though not legally binding, reflect the Commission's interpretation and will guide enforcement. Providers should review their obligations, assess model risks, prepare for compliance, and engage with the AI Office.
The guidelines for providers of GPAI model help stakeholders across the AI value chain innovate with clarity and confidence.
Submitting documents
Providers of general-purpose AI models must use the EU SEND platform to submit documents related to their obligations to the AI Office. EU SEND ensures the confidentiality, integrity, and authenticity of the information shared.
Providers of general-purpose AI models (or their authorised representatives where applicable) should submit documents related to:
- Notifications of a general-purpose AI model with systemic risk pursuant to Art 51(2) and 52(2) of the AI Act
- Requests for reassessment pursuant to Art 52(5) of the AI Act
- Reports of serious incident pursuant to Art 55(1)(c) of the AI Act
- Safety and Security Framework and Model Report pursuant to Measures 1.4 and 7.7 of the Safety and Security Chapter of the GPAI Code of Practice
- Reports on how providers of general-purpose AI models who have not signed the General-Purpose AI Code of Practice intend to comply with the AI Act, as outlined in the Guidelines on the scope of obligations for providers of general-purpose AI (GPAI) models, Section 5.1.
Download the technical guidance for submitting documents via EU SEND
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