EU AI Act News: Rules on General-Purpose AI Start Applying, Guidelines and Template for Summary of Training Data Finalized

The EU AI Act's obligations for general-purpose AI models will take effect on August 2, 2025. The European Commission has released guidelines, a code ...

Published November 2025 • Feature

## Introduction Obligations relating to general-purpose artificial intelligence (GPAI) models under the EU AI Act will enter into force on 2 August 2025. In preparation for this deadline, the European Commission has published several key documents relevant to stakeholders involved in the development and fine-tuning of AI models that utilize large volumes of data. ## Key Documents Released The European Commission has released the following documents: - **Guidelines on the Scope of Obligations for GPAI Models** (published on 18 July 2025) - **GPAI Code of Practice** (published on 10 July 2025) - **Template for the Public Summary of Training Content for GPAI Models** (published on 24 July 2025) These documents outline the obligations and expectations for GPAI model providers. ## Guidelines on the Scope of Obligations for GPAI Models The Guidelines clarify when and how the EU AI Act’s provisions apply to GPAI models. Although non-binding, the Commission will base its enforcement on these interpretations. Key topics covered include: 1. **Definition of GPAI Models**: A model is considered GPAI if its training compute exceeds 1023 floating point operations per second (FLOP) and it can generate language, text-to-image, or text-to-video outputs. 2. **Market Placement**: A GPAI model is deemed “placed on the market” when integrated into applications or AI systems available in the EU. 3. **Provider Responsibilities**: Providers outside the EU may still be subject to obligations if their models are marketed within the EU. ### Lifecycle of GPAI Models The lifecycle of a GPAI model begins with its large pre-training run. Any further development by the original provider continues this lifecycle, while modifications by downstream entities may create new obligations. ## Insights on Enforcement While obligations for GPAI model providers take effect on 2 August 2025, models placed on the market before this date have until 2 August 2027 to comply. Notably, models are not required to undergo retraining if data retrieval is impractical or burdensome. Enforcement actions by the Commission will commence on 2 August 2026. ## GPAI Code of Practice The GPAI Code of Practice is a voluntary framework that GPAI model providers can adopt. Key implications include: - **Increased Trust**: Providers adhering to the Code will benefit from enhanced trust and focused compliance monitoring. - **Compliance Requirements**: Non-signatories may face more stringent information requests and must demonstrate compliance through alternative means. The Code consists of three chapters: 1. **Transparency**: Obligations for technical documentation and information disclosure. 2. **Copyright**: Compliance with EU copyright laws and commitments regarding web-crawlers. 3. **Safety and Security**: Detailed obligations for models with systemic risk, including risk management and cybersecurity measures. ## Template for Public Summary of Training Content Unlike the non-binding Guidelines and Code of Practice, the Template is mandatory for GPAI model providers. It categorizes training data sources into: - Publicly available datasets - Private licensed datasets - Data crawled from online sources - User data - Synthetic data - Other data Providers must disclose specific information based on the data category, including measures to respect copyright and remove illegal content. ## Conclusion Stakeholders may face challenges in adapting to these new regulations ahead of the deadlines. While the Guidelines, Code of Practice, and Template provide essential guidance for compliance with the EU AI Act, the increased detail may also add to the regulatory burden. Stakeholders are encouraged to seek further clarification on how these developments may impact their operations.

Source: mayerbrown.com