What is a general-purpose AI model (GPAI)?
A general-purpose AI model (GPAI) is, under the EU AI Act, an AI model — typically trained on large amounts of data using self-supervision at scale — that displays significant generality, can competently perform a wide range of distinct tasks, and can be integrated into a variety of downstream systems or applications. Foundation models such as large language models are the paradigm case. GPAI obligations have applied since 2 August 2025, with Commission enforcement from 2 August 2026.
Core provider obligations (Art. 53)
- Technical documentation for the AI Office and downstream providers (capabilities, limitations, integration guidance);
- A copyright policy consistent with EU law, honouring text-and-data-mining opt-outs;
- A public training-content summary on the AI Office template;
- For models with systemic risk (very large training compute): model evaluations, adversarial testing, incident reporting and cybersecurity duties (Art. 55).
Why it matters for companies building on GPAI
Fine-tuning or substantially modifying a GPAI model can make you a provider for that modification — including the training-content summary for your fine-tuning data. Prompting and retrieval (RAG) generally keep you downstream. The provider/deployer boundary defines which obligations are yours; see our guide on building on foundation models and the related terms foundation model and high-risk AI system.