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European Union

EU AI Act 2025: guidance on scope and prohibited practices, GPAI code, model procurement clauses, early enforcement, liability landscape and the AI Continent Plan—action points for compliance and contracts

Published on: 28 April 2025

Published by a LexisNexis EU Law expert
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Article summary

Commission Guidance—clarifying early obligations

Since the very start of the year, the Commission has issued six notable guidance documents to help support compliance with the EU AI Act. On 4 February 2025, it unveiled the AI Literacy Repository to support Article 4, in force from 2 February 2025, which obliges organisations to actively promote AI literacy internally (see: LNB News 05/02/2025 43). The repository showcases practical training initiatives from early adopters and provides a benchmark for companies developing internal competence frameworks. On the same day, it released draft Guidelines on Prohibited AI Practices under Article 5, also applicable from February, offering legal interpretation with illustrative examples (see: LNB News 05/02/2025 39). Prohibitions include

  • subliminal manipulation,
  • exploitative systems,
  • real-time biometric surveillance, and
  • social scoring.

Although non-binding, the guidelines act as authoritative reference points for organisations and should be built directly into risk assessments. On 6 February 2025, detailed guidance on the definition of an AI system was issued (see: LNB News 07/02/2025 36). This guidance tackles scope queries by clarifying the legal criteria that determine whether a software application qualifies as an AI system under the Act. This is crucial for compliance scoping and product classification, especially for high-risk systems...

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