European Union: Implemented AI Act including obligations for providers of general-purpose AI models

On 2 August 2025, the obligations under Title VIII, Chapter V of Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (AI Act) became applicable to providers of general-purpose AI (GPAI) models, in accordance with Article 113(2). From this date, providers of GPAI models placing models on the Union market are required to comply with obligations, including the preparation and maintenance of technical documentation, the provision of training dataset summaries, publication of model evaluations, and adherence to Union copyright law. For GPAI models identified as posing systemic risk, providers are additionally required to notify the European Artificial Intelligence Office, assess and document systemic risks, implement mitigation measures, and report serious incidents. Furthermore, providers of GPAI models not established within the European Union are required to appoint an authorised representative based in the Union before placing their models on the EU market. The authorised representative must retain copies of the technical documentation and contact details for ten years and make them available to the European AI Office or national authorities upon request.