GPAI Provider Obligations (Article 53) - What Model Providers Owe Now
GPAI provider obligations are already live: since 2 August 2025, anyone placing a general-purpose AI model on the EU market owes the Article 53 set, and models that were already on the market before that date get until 2 August 2027 to catch up. If you train, fine-tune and release, or meaningfully modify a general-purpose model, this is your list.
The Article 53 checklist
| # | Obligation | Who consumes it |
|---|---|---|
| 1 | Maintain technical documentation of the model, training and testing included | Regulators (AI Office), on request |
| 2 | Provide information and documentation to downstream system providers | The companies building on your model |
| 3 | Put a copyright policy in place, honoring opt-outs from text-and-data mining | Rights holders |
| 4 | Publish a sufficiently detailed summary of the training content | The public |
Open-source models get a partial carve-out from rows 1 and 2 (not from the copyright policy or the training-content summary), and the carve-out falls away entirely if the model carries systemic risk.
Does fine-tuning make us a GPAI provider?
This is the question we hear most. Using a model via API does not. Releasing a meaningfully modified or fine-tuned general-purpose model can, with obligations scoped to your modification. The honest answer is fact-specific: document your modification's scale and your role conclusion, then have counsel confirm the close calls.
Systemic-risk models are a different game
Cross the systemic-risk threshold (the Act presumes it at 10^25 FLOPs of training compute) and Article 55 adds model evaluations, adversarial testing, incident reporting, and cybersecurity duties on top. If you are anywhere near that scale you already have lawyers; this page is for everyone else.
What we recommend this quarter
Inventory which models you provide versus merely use. For provided models, stand up the four rows above as living documents. AI Comply HQ tracks GPAI as its own tier in classification and generates the documentation scaffolding, so the Article 53 file stays current as the model evolves.
FAQ
We just call a model API inside our product. Which page is ours?
Not this one. Your product is an AI system, so start at the compliance checklist and classify it.
Map your model's obligations free
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This page is informational content, not legal advice. Talk to a qualified lawyer about your specific situation.