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, 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.

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.

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.