As of 2 August 2025, the EU AI Act Commencement date for GPAI laws has come into effect, introducing new regulatory obligations for GPAI providers. Although, earlier this year, critics warned that the law could stifle innovation, regulators admitted they weren’t ready, and transatlantic tensions sparked concern over alignment. The Commission has moved forward without delay and rules now apply directly to GPAI providers. If you are a GPAI provider, here’s what you need to know.
Who is a GPAI provider?
A GPAI provider develops or commissions the development of a General Purpose AI model and places it on the EU market, whether for payment or free of charge. The EU AI Act defines a GPAI model as an AI system that can perform a wide range of distinct tasks (i.e. text, image, audio tasks, decision support etc.) into many downstream applications (chatbots, enterprise software, recommendation engines etc.). If you place a GPAI model on the EU internal market, or put it into service under your own name, these rules apply to you. The only exception is if you use GPAI internally and it poses no risks to individuals.
Key obligations for GPAI providers
Compliance tools and guidance for GPAI providers
The Commission issued practical resources to support GPAI providers:
- Guidelines : Clarifying what a GPAI model is, who qualifies as a provider and what “placing on the market” means.
- Code of Practice : A voluntary framework covering transparency, copyright, and (for systemic risk models) safety and security. Adopting it can reduce uncertainty and compliance burdens.
- Training Data Template : A standardised way to publish summaries of training data.
Next EU AI Act commencement date
In August 2027 the EU AI Act commencement date for systemic risk GPAI laws takes effect.
A GPAI has systemic risks where due to the size (trained with more than 10^25 FLOPs), capabilities or influence across many applications, has the potential to cause widespread harm or disruption if misused. At the same time, the EU AI Office will begin supervising compliance and enforcement, with penalties of up to €35 million or 7% of global turnover for breaches.
What can your organisation do?
As jurisdictions around the world begin to roll out AI laws, compliance becomes your your launchpad and early alignment retains a competitive edge. To ensure Trusworthy AI and leverage it lawfully, take steps to:
- Assess your role in AI system supply chain (provider/deployer, etc).
- Determine the risk level of your AI system.
- Implement applicable obligations.
