Digital Lexicon Hub

Under the EU AI Act, an AI model with significant generality that can perform a wide range of distinct tasks and be integrated into many systems.

Most companies use GPAI models rather than build them, but provider duties shape the documentation they receive and can apply to a company that substantially modifies a model, so procurement and legal teams need to know where the lines fall.

A software firm fine-tunes an open model using far less than a third of the original training compute, so under Commission guidance it does not become a GPAI provider; it still requests the upstream provider's documentation for its own AI Act file.

Several thresholds are indicative and set in Commission guidance rather than the Act, and the Commission can update them. Many terms remain open to interpretation, and only the Court of Justice of the EU can interpret the Act bindingly.

The EU AI Act, Regulation (EU) 2024/1689, sets duties for GPAI providers that apply from 2 August 2025. Commission guidance uses training compute above 10^23 FLOP plus language or image generation as an indicative criterion. Article 53 requires technical documentation, information for downstream providers, a copyright policy and a public training content summary. Models above 10^25 FLOP are presumed to have systemic risk under Article 51 and face Article 55 duties such as model evaluation, incident reporting and cybersecurity.