GPAI Model Obligations in EU AI Act: What You Need to Know

The EU AI Act introduces groundbreaking regulations for General-Purpose AI (GPAI) models, creating the world’s first comprehensive legal framework for AI systems like GPT-4, Claude, and Gemini.

With obligations taking effect in August 2025, understanding these requirements is crucial for AI providers, developers, and businesses using GPAI models.

Need help with EU AI Act compliance? Our eyREACT platform simplifies GPAI obligations with automated documentation tools, compliance tracking, and expert guidance. Join our waitlist for early access and ensure you’re ready for August 2025.

What Are General-Purpose AI (GPAI) Models?

General-Purpose AI models are AI systems designed to perform a wide range of tasks rather than being built for one specific purpose. Think ChatGPT, which can write code, answer questions, create content, and solve problems across multiple domains. Unlike specialized AI (like a spam filter), GPAI models demonstrate flexibility and adaptability across various applications.

The EU AI Act specifically targets these models because of their broad capabilities and potential for widespread impact. When a single AI model can influence everything from hiring decisions to medical diagnoses, regulatory oversight becomes essential.

Key GPAI Obligations Under the EU AI Act

Technical Documentation Requirements

GPAI providers must create comprehensive technical documentation covering model architecture, training data, capabilities, and limitations. Specific documentation must Include:

• Model architecture and design specifications
• Training methodologies and computational resources used
• Data sources, collection methods, and preprocessing techniques
• Known limitations and potential risks
• Testing procedures and performance metrics
• Intended use cases and deployment guidelines

Why This Matters: This documentation serves as the foundation for regulatory compliance and helps downstream developers understand how to use the model safely and effectively.

Risk Assessment and Management

Providers must conduct thorough assessments of potential risks, including bias, safety concerns, and misuse potential. Risk categories to address:

• Fundamental rights violations
• Health and safety risks
• Environmental impact
• Cybersecurity vulnerabilities
• Potential for harmful content generation

Risk assessment isn’t a one-time activity. Providers must continuously monitor model performance and update risk evaluations as new use cases emerge.

Cybersecurity Measures under EU AI Act

Robust security requirements exceed those of GDPR. GPAI models must implement strong cybersecurity protections against various attack vectors. Required security measures inclde:

• Protection against data poisoning attacks
• Model evasion and adversarial attack resistance
• Secure model storage and transmission
• Access controls and authentication systems
• Incident response procedures

These requirements address growing concerns about AI model theft, manipulation, and unauthorized access that could compromise model integrity.

Energy Efficiency and Environmental Compliance in EU AI Act

The EU AI Act requires providers to document and optimize energy consumption during model training and deployment.
Environmental obligations include:

• Energy consumption reporting during training
• Carbon footprint documentation
• Efficiency optimization measures
• Sustainable computing practices
• Environmental impact assessments

This reflects the EU’s broader sustainability goals and recognition that training large AI models consumes significant computational resources.

High-Risk GPAI Models: Additional Requirements

Some GPAI models face enhanced obligations when they meet specific criteria for “systemic risk.” These typically include the most advanced and widely-used models.

Systemic Risk Criteria According to EU AI Act

A GPAI model is considered high-risk when it:

• Uses computational power exceeding 10^25 floating-point operations (FLOPs)
• Demonstrates advanced capabilities across multiple domains
• Has widespread deployment or user base
• Shows potential for significant societal impact

Enhanced Obligations for High-Risk Models

Thorough Model Evaluation:

• Comprehensive testing across various scenarios
• Red-teaming exercises to identify vulnerabilities
• Performance evaluation on standardized benchmarks
• Safety testing for potential harmful outputs

Serious Incident Reporting:

• Immediate notification to the European Commission
• Detailed incident analysis and impact assessment
• Corrective action documentation
• Timeline for resolution

Adversarial Testing:

• Regular penetration testing
• Stress testing under various conditions
• Evaluation of model behavior in edge cases
• Documentation of failure modes

EU AI Act Implementation Timeline: When Do These Rules Apply?

August 2, 2025: Most GPAI obligations become enforceable. Models placed on the market before August 2, 2025, have until August 2, 2027, to achieve full compliance.

Voluntary compliance is encouraged before mandatory enforcement and for that, the European Commission’s AI Office is developing detailed guidance.

Organisations using or developing GPAI models should begin compliance preparation immediately, as August 2025 is approaching rapidly.

Compliance Strategies for GPAI Providers

Start Documentation Now

Begin comprehensive technical documentation immediately. This process takes significant time and resources, and waiting until 2025 creates unnecessary compliance risks. Your most essential action items:

• Audit existing documentation gaps
• Assign dedicated teams to documentation tasks
• Establish version control and update procedures
• Create standardized documentation templates

Implement Robust Testing Frameworks

Develop systematic testing and evaluation procedures that can demonstrate compliance with safety and performance requirements. Testing components to include:

• Automated testing suites
• Human evaluation protocols
• Bias detection and mitigation tools
• Performance monitoring systems

Establish Risk Management Processes

Create formal risk management frameworks that identify, assess, and mitigate potential harms from model deployment. Process elements to include:

• Regular risk assessments
• Stakeholder consultation procedures
• Mitigation strategy development
• Ongoing monitoring and adjustment

Prepare for Regulatory Engagement

Build relationships with regulatory authorities and prepare for compliance audits and inquiries. Regulatory readiness checklist for you:

• Designate compliance officers
• Establish communication protocols with authorities
• Prepare for potential investigations
• Document compliance efforts comprehensively

Impact on Businesses Using GPAI Models

Even if you’re not developing GPAI models, your business may be affected by these regulations. Model providers must share specific information about capabilities and limitations. You may need additional documentation for your AI system that incorporates GPAI models. Transparency requirements may affect how you deploy and communicate about AI features

Due Diligence Requirements When Selecting GPAI Models:

• Verify the provider’s compliance status
• Review available technical documentation
• Understand model limitations and appropriate use cases
• Ensure your use case aligns with intended purposes

Common EU AI Act Compliance Challenges and Solutions

Challenge 1: Documentation Complexity

Problem: Technical documentation requirements are extensive and detailed.
Solution: Break documentation into manageable components and assign cross-functional teams including technical, legal, and compliance experts.

Challenge 2: Continuous Monitoring

Problem: Ongoing risk assessment and monitoring require significant resources.
Solution: Implement automated monitoring tools such as eyREACT and establish clear escalation procedures for potential issues.

Challenge 3: Regulatory Uncertainty

Problem: Some requirements remain unclear pending additional guidance from the European Commission.
Solution: Adopt conservative compliance approaches and stay engaged with industry groups and regulatory updates.

Penalties for Non-Compliance with EU AI Act

The EU AI Act establishes significant financial penalties for non-compliance: Maximum fines are quite significant:

• Up to €35 million or 7% of global annual revenue
• Specific penalty tiers based on violation severity
• Additional enforcement actions possible

 Preparing for the Code of Practice

The European Commission is developing a Code of Practice that will provide detailed implementation guidance for GPAI obligations. This code will offer more specific requirements and best practices. Some of the helpful code elements include:

• Detailed technical standards
• Implementation timelines
• Reporting templates and procedures
• Best practice recommendations

The best bet is ti stay informed and monitor European Commission AI Office announcements. Participate in industry consultation processes and engage with legal counsel familiar with EU AI Act requirements.

International Implications: Should You Worry about AI Act if You Work in USA?

While the EU AI Act applies directly only within the European Union, its impact extends globally due to the “Brussels Effect.”
Global considerations:

• GPAI models used in EU markets must comply regardless of where they’re developed
• Many providers are adopting EU standards globally to simplify operations
• Other jurisdictions are developing similar regulations based on EU AI Act principles

Conclusion: Taking Action on GPAI Compliance

GPAI model obligations under the EU AI Act represent a fundamental shift in AI regulation. With enforcement beginning in August 2025, organisations must act quickly to ensure compliance. Take these steps:

• Assess Current State: Evaluate existing GPAI models and documentation
• Gap Analysis: Identify compliance gaps and resource requirements
• Implementation Planning: Develop detailed compliance roadmaps
• Expert Consultation: Engage legal and technical experts familiar with EU AI Act requirements
• Ongoing Monitoring: Establish systems for tracking regulatory developments

The EU AI Act’s GPAI obligations mark the beginning of comprehensive AI regulation worldwide. Organizations that proactively address these requirements will be better positioned for success in an increasingly regulated AI landscape.

By understanding and preparing for these obligations now, businesses can ensure they’re ready for the August 2025 deadline while building robust AI governance frameworks that extend beyond mere compliance to create truly trustworthy AI systems.

Need help with EU AI Act compliance? Our eyREACT platform simplifies GPAI obligations with automated documentation tools, compliance tracking, and expert guidance. Join our waitlist for early access and ensure you’re ready for August 2025.