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

On 18 July 2025 the Commission published guidelines on the scope of the obligations for providers of general-purpose AI models under the AI Act, ahead of those obligations entering into application on 2 August 2025. The guidelines address which models and which actors fall within the GPAI provisions — including when modifying or fine-tuning a model makes you its provider.

Whether you are a 'provider of a GPAI model' determines whether the Act's most technical documentation and copyright obligations land on you or on your supplier. Fine-tuning teams can cross that line without realising it.

Organisations that build, substantially modify or fine-tune general-purpose models — and AI leads assessing whether internal model work triggers provider obligations.

Assess against the guidelines whether any of your model work makes you a GPAI provider; if it does, scope the documentation, copyright-policy and transparency duties that follow.