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EU AI Act GPAI guidelines: model definition and lifecycle, provider/market placement, open-source exemptions, systemic-risk thresholds, enforcement by EU AI Office, Code of Practice, and compliance timelines

Published on: 30 July 2025

Published by a LexisNexis EU Law expert
Legal News
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Article summary

The Commission has issued its ‘Guidelines on the scope of obligations for general‑purpose AI models’. Though not legally binding, they explain how the Commission reads and applies Regulation (EU) 2024/1689 (the EU AI Act), which will underpin its enforcement practice and thus offer significant practical clarity. They succeed a prior draft circulated in April 2025 for consultation (see: LNB News 18/07/2025 40 and LNB News 22/04/2025 37). The final text concentrates on four central and closely linked themes: defining GPAI models, what counts as a provider placing a GPAI model on the market, the open‑source exemptions to the obligations for GPAI models, and certain considerations on the enforcement of the GPAI model framework.

What is a GPAI model?

The guidelines set out three key elements about GPAI models: an indicative benchmark for when a model qualifies as a GPAI model, how the ‘lifecycle’ of a GPAI model is understood, and when a GPAI model presents systemic risk...

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