EU AI Rules Now Apply to General-Purpose AI Models
EU AI Rules Now Apply to General-Purpose AI Models
August 2025
Anastasia Dritsa, Partner, and Io Ligeraki, Junior Associate
Kyriakides Georgopoulos Law Firm
As of 2 August 2025, the European Union’s landmark AI Act has officially entered into application for general-purpose AI (GPAI) models, setting a new global benchmark for transparency, safety and accountability in artificial intelligence.
A GPAI model is defined as one trained using more than 10²³ floating point operations (FLOPs) and capable of generating language (text or audio), text-to-image, or text-to-video outputs. Providers of high-impact GPAI models — those trained with more than 10²⁵ FLOPs and posing systemic risks — face additional obligations, including mandatory notification to the European Commission and the implementation of enhanced safety and security measures.
From this point forward, GPAI providers must comply with key requirements, including disclosing information about model training, respecting copyright protections and ensuring the responsible development of their AI systems.
To support implementation, the European Commission has issued detailed guidelines outlining the scope of GPAI obligations under the AI Act.
Key aspects include:
- Clear criteria: Definitions and thresholds to determine when a model qualifies as “general-purpose,” helping developers assess their legal obligations.
- Practical approach: Only providers making significant modifications to GPAI models must comply with full obligations — minor changes do not trigger compliance.
- Open-source exemptions: Conditions under which open-source model providers are exempt, supporting innovation while reducing unnecessary burden.
A key component of the compliance framework is the newly launched GPAI Code of Practice, published on 10 July 2025. Developed by independent experts through a multi-stakeholder process, the Code is a voluntary tool that helps industry align with the AI Act’s obligations and consists of three separately authored chapters:
- Transparency: Offers a Model Documentation Form to help providers present essential information in a user-friendly and consistent manner.
- Copyright: Provides practical guidance on establishing internal policies to comply with EU copyright law.
- Safety: Outlines state-of-the-art practices for assessing and mitigating systemic risks posed by advanced GPAI models.
Both the Commission and the AI Board have confirmed its adequacy as a compliance pathway, offering providers legal certainty and reduced regulatory burden if adopted.
Next Steps:
GPAI providers placing new models on the EU market must now meet transparency and copyright obligations. From 2 August 2026, the European Commission’s enforcement powers come into effect, allowing for formal compliance checks and the imposition of fines. By 2 August 2027, all GPAI models already on the market before the initial application date must also meet the regulatory requirements.
Providers are strongly encouraged to make use of the Code of Practice and Commission guidance to support timely and effective compliance.
August 2025
Anastasia Dritsa, Partner, and Io Ligeraki, Junior Associate
Kyriakides Georgopoulos Law Firm
As of 2 August 2025, the European Union’s landmark AI Act has officially entered into application for general-purpose AI (GPAI) models, setting a new global benchmark for transparency, safety and accountability in artificial intelligence.
A GPAI model is defined as one trained using more than 10²³ floating point operations (FLOPs) and capable of generating language (text or audio), text-to-image, or text-to-video outputs. Providers of high-impact GPAI models — those trained with more than 10²⁵ FLOPs and posing systemic risks — face additional obligations, including mandatory notification to the European Commission and the implementation of enhanced safety and security measures.
From this point forward, GPAI providers must comply with key requirements, including disclosing information about model training, respecting copyright protections and ensuring the responsible development of their AI systems.
To support implementation, the European Commission has issued detailed guidelines outlining the scope of GPAI obligations under the AI Act.
Key aspects include:
- Clear criteria: Definitions and thresholds to determine when a model qualifies as “general-purpose,” helping developers assess their legal obligations.
- Practical approach: Only providers making significant modifications to GPAI models must comply with full obligations — minor changes do not trigger compliance.
- Open-source exemptions: Conditions under which open-source model providers are exempt, supporting innovation while reducing unnecessary burden.
A key component of the compliance framework is the newly launched GPAI Code of Practice, published on 10 July 2025. Developed by independent experts through a multi-stakeholder process, the Code is a voluntary tool that helps industry align with the AI Act’s obligations and consists of three separately authored chapters:
- Transparency: Offers a Model Documentation Form to help providers present essential information in a user-friendly and consistent manner.
- Copyright: Provides practical guidance on establishing internal policies to comply with EU copyright law.
- Safety: Outlines state-of-the-art practices for assessing and mitigating systemic risks posed by advanced GPAI models.
Both the Commission and the AI Board have confirmed its adequacy as a compliance pathway, offering providers legal certainty and reduced regulatory burden if adopted.
Next Steps:
GPAI providers placing new models on the EU market must now meet transparency and copyright obligations. From 2 August 2026, the European Commission’s enforcement powers come into effect, allowing for formal compliance checks and the imposition of fines. By 2 August 2027, all GPAI models already on the market before the initial application date must also meet the regulatory requirements.
Providers are strongly encouraged to make use of the Code of Practice and Commission guidance to support timely and effective compliance.
