Skip to content

Guidance

Commission guidelines clarify who counts as a provider of a general-purpose AI model

Guidance18 Jul 2025✓ verified 24 Aug 2026

Commission guidelines of 18 July 2025 set out who counts as a GPAI provider — including when fine-tuning makes you one — with obligations applying from 2 August 2025 and Commission enforcement from 2 August 2026.

What changed

On 18 July 2025 the Commission published guidelines on the scope of the obligations for providers of general-purpose AI models, ahead of those obligations entering into application on 2 August 2025. The guidelines set technical criteria for when a model is general-purpose, and take a pragmatic line on the supply chain: only significant modifications to a model trigger provider obligations for the modifier — minor changes do not. They also clarify the conditions under which providers of open-source models are exempt from certain obligations. On timing: provider obligations have applied since 2 August 2025; the Commission's enforcement powers, including fines, apply from 2 August 2026; and models placed on the market before 2 August 2025 must be brought into compliance by 2 August 2027.

Why it matters

Whether you are a 'provider of a GPAI model' determines whether the Act's most technical documentation and copyright obligations land on you or stay with your supplier. Fine-tuning teams can cross the significant-modification line without realising it — and with Commission enforcement powers live from 2 August 2026, the cost of getting that call wrong is about to become concrete.

Who is affected

Organisations that build, substantially modify or fine-tune general-purpose models; open-source model publishers checking their exemption conditions; and AI governance leads mapping which entity in the chain owes which obligation.
RolesAI governance leadslegal teamscompliance teamsengineering leads
OrganisationsGPAI model providersAI providersopen-source model publishers

What to check next

  • Identify all model work in your organisation (training, fine-tuning, substantial modification) and assess each against the guidelines' significant-modification criteria
  • Document the provider/non-provider conclusion per model, with reasoning
  • Confirm whether open-source exemption conditions apply to any models you publish
  • Map the timeline to your models: obligations since 2 August 2025, Commission enforcement from 2 August 2026, legacy models compliant by 2 August 2027
  • Prepare the documentation, copyright-policy and transparency work for any model where you are the provider

Key dates

  • 2025-07-18Guidelines published
  • 2025-08-02GPAI provider obligations apply
  • 2026-08-02Commission enforcement powers (including fines) apply
  • 2027-08-02Models placed on the market before 2 August 2025 must be in compliance
Source. European Commission — guidelines on GPAI provider obligations ↗
Document: Commission guidelines on the scope of GPAI provider obligations (AI Act)
Verified by Trusq against this source on 24 Aug 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.
Relates to AI Act
← All updates