GPAI deadline page for providers of general-purpose AI models, including foundation models and LLMs offered to others.
In effect
Obligations for providers of general-purpose AI models apply, including technical documentation, information to downstream providers, copyright-policy duties, and additional duties for systemic-risk models.
GPAI duties are aimed at providers of general-purpose AI models: the companies that make a model available for other developers, integrators, or business users to build on. In practical terms, the work is about knowing what model you are providing, keeping technical documentation in a form that can be shared when needed, giving downstream providers enough information to use the model responsibly, and maintaining a copyright policy. If the model has systemic-risk exposure, the work does not stop at a model card. It needs a deeper internal process for documenting risks, changes, and how the model is released.
A company that trains and offers a foundation model through an API is the clearest case. An open-weight model publisher can also be in the conversation if it is providing a general-purpose model for others to adapt. A vertical software company may trigger this if it is not merely using someone else’s model, but packaging and offering its own general-purpose model layer to customers or partners.
The common mistake is assuming this only applies to consumer chatbots. The deadline data is about model providers, not only chatbot operators. A business can avoid a chatbot UI entirely and still have GPAI exposure if it provides a model that downstream teams can use across many tasks. The opposite mistake also happens: a normal business user of a third-party model may have other AI Act duties, but it is not automatically the GPAI model provider.
Start by separating three roles: model provider, downstream provider, and deployer. Then list every model your company trains, fine-tunes, hosts, or exposes to others. For each one, identify what documentation exists, what information downstream users receive, and who owns copyright-policy review. If you may have systemic-risk exposure, escalate that question early. Do not wait for procurement or product launch to discover that the model documentation is incomplete.
