AI Act guidelines: scope of obligations for providers of general-purpose AI (GPAI) models
Published by the Commission on 18 July 2025, these guidelines explain the scope of AI Act obligations for GPAI model providers: what a GPAI model is, who is a 'provider', what 'placing on the market' means, exemptions for open-source models and the effect of adhering to the GPAI Code of Practice. As an indicative criterion, a model trained with more than 10^23 FLOP that can generate language (text or audio), text-to-image or text-to-video is a GPAI model. GPAI obligations apply from 2 August 2025; models already on the market must comply by 2 August 2027.
Timeline
- 18 Jul 2025AuthoritiesCommission publishes these guidelines
- 2 Aug 2025Obligations for GPAI model providers apply
- 2 Aug 2026AuthoritiesCommission (AI Office) enforcement powers apply
- 2 Aug 2027GPAI models placed on the market before 2025-08-02 must comply
Key facts
- Reference
- Commission Guidelines on the scope of obligations for GPAI models (18.7.2025)
- Adopted
- 18 Jul 2025
- Published
- 18 Jul 2025
- Status
- In force
- Amendments
- Interprets GPAI obligations in Articles 3 and 51 to 55 of Reg (EU) 2024/1689 (AI Act)
- Topic
- Cybersecurity & Data
- Industries
- Cross-sector
Main compliance requirements
Paid members only
The main compliance requirements, applicability questions and penalties are available in the ZC Smart Compliance Hub. Paid members and clients can sign in to the Hub to view them.
Related legislation
- Interprets Chapter V (Articles 51 to 56) GPAI obligations of Regulation (EU) 2024/1689 (AI Act, as amended by Regulation (EU) 2026/1744). Related: GPAI Code of Practice (2025-07-10), training content summary template (2025-07-24).
Official sources
Guidelines on the scope of the obligations for general-purpose AI models established by Regulation (EU) 2024/1689 (AI Act)
Full text on EUR-Lex (Commission Guidelines on the scope of obligations for GPAI models (18.7.2025))