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General-purpose AI models, GPAI are not only integrated into the European AI legal systems (i.e. the AI Act), they play significant roles in encouraging the EU-wide digital innovations and uptake. The second day this August has become a great day for the EU-wide digital transition process: most of the AI Act obligations for GPAI providers enter into application. However, the GPAI models’ providers are also having certain obligations under the AI Act.
Background
European AI Act’s obligations for providers of general-purpose AI models aim to ensure that general-purpose AI models are transparent, in line with EU and national copyright law, and that providers of the most advanced or most impactful general-purpose AI models assess and mitigate the systemic risks presented by these models. To help providers of general-purpose AI models comply with the AI Act, the Commission is making available a package of information, which includes the guidelines, the General-Purpose AI Code of Practice, and further tools to assist providers, such as the AI Act Service Desk.
The guidelines were developed through a public consultation, during which the Commission gathered input from hundreds of stakeholders. They also reflect input from the expert pool set up by the Commission’s Joint Research Centre to advise the AI Office on the classification of AI models, including general-purpose AI models and those with systemic risk, as well as feedback from other experts.
While not legally binding, these guidelines set out the Commission’s interpretation and application of the AI Act, which will guide its enforcement actions.
Reference to: https://digital-strategy.ec.europa.eu/en/news/eu-rules-general-purpose-ai-models-start-apply-tomorrow-bringing-more-transparency-safety-and
Supporting guidelines
To assist providers, the Commission published guidelines*) clarifying the procedural aspects concerning compliances with the legal obligations. Thus, the GPAI providers (classified as general-purpose AI models with systemic risk) must notify the AI Office without delay. In the first year after entry the act enter into application, the AI Office will work closely with providers, in particular those who adhere to the General-Purpose AI Code of Practice, to help them comply with the rules; from 2 August 2026, the Commission’s enforcement powers enter into application.
The GPAI models are defined in the guidelines as those “trained with over 10^23 FLOP and capable of generating language”.
These guidelines clarify the scope and application of legal obligations; they are focusing on the following issues:
1. General-purpose AI models: An AI model is considered to be a general-purpose AI model if it was trained using an number of computational resources (‘compute’) that exceeds 10^23 floating point operations and if it can generate language (whether in the form of text or audio), text-to-image or text-to-video.
2. Providers of general-purpose AI models: The guidelines outline the concepts of a ‘provider’ and of ‘placing on the market’ and clarify when an actor modifying a general-purpose AI model is considered to become a provider.
3. Exemptions from certain obligations: The guidelines clarify under what conditions providers of general-purpose AI models released under a free and open-source license and satisfying certain transparency conditions may be exempt from certain obligations under the AI Act.
4. Enforcement of obligations: The guidelines explain the implications for providers of general-purpose AI models that choose to adhere and implement the General-Purpose AI Code of Practice, and outline Commission expectations regarding compliance as from 2 August 2025.
*) More on guidelines in: https://digital-strategy.ec.europa.eu/en/news/learn-more-about-guidelines-providers-general-purpose-ai-models
The Commission and the EU member states have also confirmed that the GPAI Code of Practice, developed by independent experts, is an adequate voluntary tool for providers of GPAI models to demonstrate compliance with the AI Act. Providers who sign and adhere to the Code will benefit from reduced burden and increased legal certainty.
Thus, as from the second of August, providers must comply with transparency and copyright obligations when placing GPAI models on the EU market; models that are already on the market before 2 August 2025 must ensure compliance with the GPAI Code in a year’s time – by 2 August 2027. Providers of the most advanced or impactful models presenting systemic risks, i.e. those exceeding 10^25 FLOP, will need to meet additional obligations, such as notifying the Commission and ensuring the model’s safety and security.
More information is available in the enforcement timeline for GPAI model; a fact-page with further details is also available online.
Additional template
The Commission published additionally (on 24 July 2025) a template to help providers in summarising the data used to train their models.
The template is a simple, uniform and effective manner for GPAI providers to increase transparency in line with the AI Act, including making such a summary publicly available.
The template is part of a broader Commission’s initiative linked to the EU-wide rules for general-purpose AI models effective from 2 August 2025; it complements the guidelines on the scope of the rules for general-purpose AI models, published 18 July, and the General-Purpose AI Code of Practice released on 10 July 2025.
On template, aka the additional clarification, in: https://digital-strategy.ec.europa.eu/en/news/commission-presents-template-general-purpose-ai-model
Bottom-line: According tom the Commission’s press release, the legal aspects in the GPAI models’ providers are bringing more transparency, safety and accountability to AI systems on the European single market, as these rules mean clearer information about how AI models are trained, with better enforcement of copyright protections and more responsible AI deployment.
More information in the following Commission websites: = the AI Act; = Commission Opinion on the assessment of the General-Purpose AI Code of Practice; = GPAI Code of Practice; = Drawing-up a General-Purpose AI Code of Practice, and = the AI Board.
Besides, there are some supporting articles on the issue in the EII’s file, e.g. = https://www.integrin.dk/2025/07/31/european-code-of-practice-for-general-purpose-ai-enters-into-force/; and = https://www.integrin.dk/2025/07/19/assisting-general-purpose-ai-models-providers-new-guidelines/