Operational guidance, not legal advice. This page distills named public sources (regulator guidance and industry practice). It is not a legal determination, not a notification decision, and not a substitute for your counsel, insurer, or a retained DFIR firm. Verify applicability and current deadlines for your facts and jurisdiction.
What GPAI-provider obligations does the EU AI Act impose?
Updated
Chapter V of Regulation (EU) 2024/1689 sets GPAI-model duties. Article 53 is the provider baseline: Annex XI technical documentation, Annex XII downstream information, a copyright policy, and a public training-content summary. Not legal advice. This page does not determine that YOU are a GPAI provider.
GPAI requirements, last verified 9 September 2026 against Chapter V (Articles 51–56), Annexes XI and XII, Article 111(3) and Article 113(b) of Regulation (EU) 2024/1689 (OJ L 2024/1689, 12.7.2024). Commission AI Act pages, the AI Office GPAI-scope guidelines, the GPAI Code of Practice, and the AI Office training-content template are Commission / AI Office materials — guidance, not the regulation. The Code of Practice is voluntary and does not replace Article 53. This page is not legal advice, not a filing, not a determination that YOU are a GPAI provider, and does not start a clock.
This is Article 53's baseline, not YOUR provider file
Audience: an engineering leader, founder, or counsel shipping or integrating a foundation model and walking Regulation (EU) 2024/1689 Chapter V. This page is not legal advice. It does not start a clock. Reading it does not start a clock. Mapping a row is not a determination that the Act applies, that YOU are a GPAI provider, or that a model has been placed on the Union market. This page does not file with the AI Office.
The AI Act is Regulation (EU) 2024/1689 of 13 June 2024, OJ L 2024/1689, 12.7.2024. ELI: http://data.europa.eu/eli/reg/2024/1689/oj. Chapter V (Articles 51–56) is the general-purpose AI model chapter. The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. Last verified 9 September 2026. Not legal advice.
- Statute versus guidance: Articles 51–56, Annexes XI and XII, Article 111(3) and Article 113(b) of 2024/1689 are legal requirements only if they apply. Commission AI Act pages, AI Office GPAI-scope guidelines, the GPAI Code of Practice, and the AI Office training-content template are Commission / AI Office materials — guidance, not the regulation. This page quotes which kind of text it is relying on.
- The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-systemic-risk guide on this site is the Article 51–55 page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page.
- This page does not invent a 2 August 2026 start date for GPAI. Article 113(b) of 2024/1689 applies Chapter V from 2 August 2025, with the exception of Article 101. Article 113(c) Annex I product-embedded high-risk is 2 August 2027, not 2026. This page does not invent a 2 August 2026 date for Annex I.
What Article 3(63) and Chapter V actually say
Last verified 9 September 2026 against Article 3(63) of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Article 3(63): 'general-purpose AI model' means an AI model, including where such an AI model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except AI models that are used for research, development or prototyping activities before they are placed on the market. That is the legal requirement. This page does not apply it to YOU.
Chapter V is a separate track from the system-risk pyramid (prohibited practices, high-risk systems, Article 50 transparency). Article 51 classifies GPAI models with systemic risk. Article 52 is the notification and designation procedure for that class. Article 53 is the baseline for providers of GPAI models. Article 54 is the authorised-representative duty for third-country providers. Article 55 adds extras for GPAI models with systemic risk — the GPAI-systemic-risk guide on this site is the Article 51–55 page. Article 56 is codes of practice. This page does not find that YOU are a GPAI provider and does not run the systemic-risk threshold. Not legal advice.
Commission GPAI-scope guidelines (published 18 July 2025) discuss how the Commission reads 'provider' and 'placing on the market', including modification of a third-party model. Those guidelines are Commission materials — guidance, not the regulation. This page does not run the fine-tuning test. Counsel reads Article 3(63) and, if useful, those guidelines as guidance. Last verified 9 September 2026.
Article 113(b) is 2 August 2025, not 2 August 2026
Last verified 9 September 2026 against Article 113 of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Article 113(b): Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101. Chapter V is the GPAI chapter. GPAI-provider duties in Articles 51–56 therefore apply from 2 August 2025 under Article 113(b), except Article 101. They did not start on 2 August 2026. This page does not move that date.
Article 101 (Commission fines for providers of GPAI models) is the exception named in Article 113(b). Article 113(c) keeps Article 6(1) and the corresponding obligations — Annex I product-embedded high-risk — on 2 August 2027, not 2 August 2026. This page does not invent a 2 August 2026 date for Annex I. Those dates are not one number.
Article 111(3) of 2024/1689: providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027. That is a legal requirement of the original regulation, only if it applies. It is not Article 113(c). This page does not decide that YOUR model was placed on the market before 2 August 2025. Not legal advice.
Article 53 baseline — provider deliverables, not YOUR file
Each row is a duty as the cited text states it. Mapping a row is not a finding that it binds YOU. Walk the checklist questions below with counsel. Last verified 9 September 2026. Not legal advice.
| Duty | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Article 53(1)(a) — technical documentation (Annex XI) | Providers of general-purpose AI models shall draw up and keep up-to-date the technical documentation of the model, including its training and testing process and the results of its evaluation, which shall contain, at a minimum, the information set out in Annex XI for the purpose of providing it, upon request, to the AI Office and the national competent authorities. | Article 53(1)(a) and Annex XI of 2024/1689. Legal requirement. This product does not produce Annex XI technical documentation for you. | 9 September 2026 |
| Article 53(1)(b) — information for downstream providers (Annex XII) | Draw up, keep up-to-date and make available information and documentation to providers of AI systems who intend to integrate the general-purpose AI model into their AI systems. Without prejudice to IP and trade secrets, that information shall enable those providers to have a good understanding of the capabilities and limitations of the model and to comply with their obligations, and shall contain, at a minimum, the elements set out in Annex XII. | Article 53(1)(b) and Annex XII of 2024/1689. Legal requirement. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. | 9 September 2026 |
| Article 53(1)(c) — copyright policy, including DSM Directive Article 4 TDM reservation | Put in place a policy to comply with Union law on copyright and related rights, and in particular to identify and comply with, including through state-of-the-art technologies, a reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790. | Article 53(1)(c) of 2024/1689. Legal requirement. Directive (EU) 2019/790 Article 4(3) is the TDM reservation. The copyright-policy guide on this site is the Article 53(1)(c) page. | 9 September 2026 |
| Article 53(1)(d) — public training-content summary | Draw up and make publicly available a sufficiently detailed summary about the content used for training of the general-purpose AI model, according to a template provided by the AI Office. | Article 53(1)(d) of 2024/1689 is a legal requirement. The AI Office template (explanatory notice of 24 July 2025) is AI Office material — guidance on the form, not a substitute for the article. The training-data-transparency guide on this site is the Article 53(1)(d) page. | 9 September 2026 |
| Article 53(3) — cooperation | Providers of general-purpose AI models shall cooperate as necessary with the Commission and the national competent authorities in the exercise of their competences and powers pursuant to this Regulation. | Article 53(3) of 2024/1689. Legal requirement. This page does not file with the AI Office. | 9 September 2026 |
| Article 54 — authorised representative for third-country providers | Prior to placing a general-purpose AI model on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union. The mandate empowers that representative to verify Annex XI documentation and Article 53 (and, where applicable, Article 55) fulfilment, keep Annex XI documentation for 10 years after the model has been placed on the market, and cooperate with the AI Office. | Article 54 of 2024/1689. Legal requirement, only if it applies. This page does not appoint YOUR representative and does not file the mandate. | 9 September 2026 |
| Article 56 — codes of practice | Providers of general-purpose AI models may rely on codes of practice within the meaning of Article 56 to demonstrate compliance with Article 53(1) until a harmonised standard is published. Providers who do not adhere to an approved code of practice or do not comply with a European harmonised standard shall demonstrate alternative adequate means of compliance for assessment by the Commission. | Article 53(4) and Article 56 of 2024/1689. Legal requirement that the code is a permitted route. The GPAI Code of Practice itself is a voluntary tool — guidance, not the regulation. It does not replace Article 53. | 9 September 2026 |
Open-source exemption — quote Article 53(2), do not paraphrase it
Last verified 9 September 2026 against Article 53(2) of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Authentic text: The obligations set out in paragraph 1, points (a) and (b), shall not apply to providers of AI models that are released under a free and open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available. This exception shall not apply to general-purpose AI models with systemic risks.
Points (a) and (b) are technical documentation and downstream-provider information. Points (c) and (d) — the copyright policy and the public training-content summary — are not in that exception. Article 54(6) uses the same licence conditions for the authorised-representative duty, unless the model presents systemic risks. This page does not find that YOUR licence qualifies, that YOUR parameters are publicly available, or that the systemic-risk carve-out is off. Counsel reads the authentic paragraph. Not legal advice.
Article 55 systemic-risk extras are not this page
Article 55 of 2024/1689 adds duties for providers of GPAI models with systemic risk, in addition to Articles 53 and 54: model evaluation including adversarial testing, systemic-risk assessment and mitigation, serious-incident tracking and reporting, and cybersecurity of the model and its physical infrastructure. Article 51(2) presumes high-impact capabilities when training compute exceeds 10^25 floating-point operations. Those extras, the presumption, and the Article 52 notification are the GPAI-systemic-risk guide on this site. This page does not run the systemic-risk threshold and does not notify the Commission. Last verified 9 September 2026. Not legal advice.
Legal requirement versus Commission and AI Office guidance
The table below labels each text. Do not treat guidance as the article, and do not treat the article as optional because a Code of Practice exists. Last verified 9 September 2026. Not legal advice.
| Text | What it is | What this page does not do |
|---|---|---|
| Regulation (EU) 2024/1689 Articles 51–56, Annexes XI and XII, Article 111(3), Article 113(b) | Legal requirement — the regulation, only if it applies. Chapter V GPAI from 2 August 2025 under Article 113(b), except Article 101. | Does not determine that YOU are a GPAI provider. Does not date GPAI from 2 August 2026. |
| Directive (EU) 2019/790 Article 4(3) — TDM reservation of rights | Legal requirement of the DSM Directive, as Article 53(1)(c) of 2024/1689 points to it. | Does not write YOUR copyright policy and does not scan YOUR training corpus. |
| European Commission AI Act page and AI Act Service Desk | Commission materials. Guidance, not the regulation. | Does not treat a Commission timeline as rewriting Article 113(b). |
| Commission guidelines on the scope of obligations for providers of GPAI models (18 July 2025) | Commission materials. Guidance, not the regulation. They discuss who is in scope, including modification of a third-party model. | Does not run the fine-tuning test. Does not treat a 10^23 FLOP discussion in those guidelines as Article 3(63). |
| EU AI Office GPAI Code of Practice (published 10 July 2025) | Commission / AI Office guidance, not the regulation. A voluntary tool. Article 53(4) permits relying on an Article 56 code to demonstrate compliance until a harmonised standard is published. | Does not treat the Code as replacing Article 53 or Article 55. |
| AI Office template for the public summary of training content (24 July 2025) | AI Office material — the template Article 53(1)(d) says to use. Guidance on the form, not a substitute for the article. | Does not fill the template for YOU and does not publish YOUR summary. |
What to do now
As of last verification on 9 September 2026, Chapter V GPAI-provider duties have applied since 2 August 2025 under Article 113(b), except Article 101. Article 111(3) gives providers of models placed on the market before 2 August 2025 until 2 August 2027 to take the necessary steps. The list below is operational preparation. It is not a determination that YOU are a GPAI provider. Walk it with counsel.
- Ask counsel whether YOU are a provider of a general-purpose AI model under Articles 3(3) and 3(63). This page does not run that test. Fine-tuning a third-party model is a question for counsel against those articles and, as guidance, the Commission GPAI-scope guidelines. Marking eu_ai_act in an obligation map is not that determination.
- If counsel finds the baseline applies, walk Article 53(1)(a)–(d), Article 53(3), and Article 54 against YOUR facts. This product does not produce Annex XI technical documentation for you and does not file with the AI Office.
- Do not treat the GPAI Code of Practice as a substitute for Article 53. It is voluntary. Do not date GPAI from 2 August 2026. Article 113(b) is 2 August 2025.
- The GPAI-systemic-risk guide on this site is the Article 51–55 page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page. The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page.
Checklist
This is a question list, not a filing, and not YOUR notice. Walk it with counsel. The EU AI Act overview on this site is the pillar page.
- Does the Act apply to YOU at all? Articles 2 and 3. This page does not run that test.
- Are YOU a provider of a general-purpose AI model? Articles 3(3) and 3(63). This page does not determine that YOU are a GPAI provider. Fine-tuning is not decided here.
- Which Article 53(1) points, if any — (a) Annex XI documentation, (b) Annex XII downstream information, (c) copyright policy including DSM Directive Article 4 TDM reservation, (d) public training-content summary using the AI Office template? This page does not pick YOUR points.
- Does Article 53(2) as quoted above actually apply to YOUR licence and YOUR parameters? Points (c) and (d) are not in that exception. This page does not qualify YOUR licence.
- If established in a third country, does Article 54 require an authorised representative in the Union before placing the model on the Union market? This page does not appoint one.
- Article 113(b) is 2 August 2025, not 2 August 2026. Article 111(3) is 2 August 2027 for models already on the market before 2 August 2025. Article 113(c) Annex I is 2 August 2027, not 2026.
- The GPAI Code of Practice is voluntary and does not replace Article 53.
- Document the assessment, including a not-a-GPAI-provider decision. This page does not keep YOUR file.
Where this shows up in ShipReady Metrics
The bundled framework key eu_ai_act is customer-visible. Its version label is Regulation (EU) 2024/1689 high-risk obligations (starter subset). It is not in INTERNAL_TESTER_ONLY_FRAMEWORKS. The control-set is a starter subset, illustrative, to be tailored by a compliance owner; not legal advice; not a conformity determination; not CE marking. Readiness is not compliance and not an EU-database registration.
If you already have a session: signed-in app → Compliance → AI governance holds the AI inventory and AI-governance posture. The AI risk register lives with that AI-governance surface. That inventory does not classify YOUR model under Article 3(63) or Article 51, does not decide that YOU are a GPAI provider, and does not file with the AI Office or a market-surveillance authority. Marking in-scope is not a provider determination and not auto-filing. A named human still owns the assessment.
This product does not produce Annex XI technical documentation for you, does not fill the AI Office training-content template, does not write a copyright policy, does not appoint an authorised representative, does not file with the AI Office, and does not issue certifications. The obligation map lists frameworks the organisation has marked in-scope, including eu_ai_act if that mark is set. Marking eu_ai_act in-scope is not a determination that you are a GPAI provider.
This page does not document a public demo URL. There is no public EU AI Act demo path. This product does not start a clock.
Primary sources (last verified 9 September 2026)
Every regulatory or guidance claim on this page is taken from one of these. If a later revision of a source changes the rule, the date above is how you can see we have not re-checked yet.
Regulation (EU) 2024/1689 of 13 June 2024 (Artificial Intelligence Act), Articles 3(63), 51–56, 111(3) and 113(b) and Annexes XI and XII, is a legal requirement only if it applies. Entry into force 1 August 2024. Article 113(b) applies Chapter V from 2 August 2025, with the exception of Article 101. Article 113(c) Article 6(1) from 2 August 2027. The European Commission's AI Act page and the AI Act Service Desk are Commission materials, not the regulation. Commission GPAI-scope guidelines (18 July 2025), the GPAI Code of Practice (10 July 2025), and the AI Office training-content template (24 July 2025) are agency/Commission guidance, not the regulation. The Code of Practice is voluntary and does not replace Article 53. These are not a complete world list. Not legal advice.
The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The EU AI Act framework guide on this site is the education page under frameworks. The GPAI-systemic-risk guide on this site is the Article 51–55 page. The technical-documentation guide on this site is the Articles 11 and 53 Annex IV/XI/XII page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page.
Frequently asked questions
Is this legal advice?
No. It is a dated map of Chapter V GPAI-provider duties distilled from Regulation (EU) 2024/1689, with Commission and AI Office materials labelled as guidance, not the regulation. Whether YOU are a GPAI provider, and which duties bind YOU, is a legal question for counsel on your facts. This page does not start a clock and does not file with the AI Office.
Does this page determine that we are a GPAI provider?
No. Mapping a row is not a determination that the Act applies, that YOU are a provider under Article 3(3), or that a model is a general-purpose AI model under Article 3(63). Counsel applies those articles to YOUR facts. Last verified 9 September 2026.
Does fine-tuning a third-party model make us a GPAI provider?
This page does not run that test. Counsel reads Article 3(63) of Regulation (EU) 2024/1689 and the Commission / AI Office GPAI-scope guidelines (18 July 2025). Those guidelines are guidance, not the regulation. Marking eu_ai_act in-scope is not a provider determination. Last verified 9 September 2026.
Does the GPAI Code of Practice replace Article 53?
No. The GPAI Code of Practice is a voluntary tool. Article 53(4) permits relying on an Article 56 code of practice to demonstrate compliance with Article 53(1) until a harmonised standard is published. Providers who do not adhere to an approved code still have to demonstrate alternative adequate means of compliance. The Code is guidance, not the regulation, and is not a substitute for Article 53. Last verified 9 September 2026.
Did GPAI obligations start on 2 August 2026?
No. Article 113(b) of Regulation (EU) 2024/1689 applies Chapter V from 2 August 2025, with the exception of Article 101. That is not 2 August 2026. Article 111(3) gives providers of GPAI models placed on the market before 2 August 2025 until 2 August 2027 to take the necessary steps. Article 113(c) Annex I product-embedded high-risk is 2 August 2027, not 2026. Last verified 9 September 2026.
Does ShipReady produce Annex XI documentation, or file with the AI Office?
No. This product does not produce Annex XI technical documentation for you, does not fill the AI Office training-content template, does not file with the AI Office, and does not issue certifications. Signed-in app → Compliance → AI governance holds the AI inventory and AI-governance posture the organisation recorded. Marking in-scope is not a provider determination and not auto-filing. A named human still owns the assessment.
Published by ShipReady Metrics, an evidence-based technology and compliance intelligence platform. This guide is educational and vendor-neutral.