{"meta":{"dataset_id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","dataset_version":"2.2.0","schema_version":"1.5.0","lang":"en","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","count":1,"filters":{"id":"praxikon:eu:ai-act:obligation:article-52-systemic-risk-classification","type":"obligation","role":null,"duty_holder":null,"topic":null},"identifiers":{"canonical_namespace":"praxikon","canonical_form":"praxikon:<jurisdiction>:<regulation>:<type>:<slug>","legacy_namespace":"raip","legacy_resolution":"permanent","resolved":{"id":"praxikon:eu:ai-act:obligation:article-52-systemic-risk-classification","role":null,"duty_holder":null}}},"data":[{"id":"praxikon:eu:ai-act:obligation:article-52-systemic-risk-classification","legacy_id":"raip:obligation:article-52-systemic-risk-classification","type":"obligation","slug":"article-52-systemic-risk-classification","version":"1.0.0","effective_at":"2025-08-02T00:00:00.000Z","known_at":"2026-08-14T00:00:00.000Z","valid_until":null,"payload_hash_sha256":"fda72f0c021ed141ad0881c569a2e4d7e59aefdcec7c95a562b9f547352a974e","label":"Article 52: notification of a GPAI model with systemic risk","summary":"The provider of a general-purpose AI model that meets the condition in Article 51(1), point (a), notifies the Commission without delay and in any event within two weeks, with the information needed to demonstrate that the requirement has been met. With that notification the provider may present substantiated arguments that the model exceptionally does not present systemic risks after all.","topics":["gpai-systemic-risk"],"actor_ids":["praxikon:eu:ai-act:actor:gpai-model-provider"],"duty_holder_ids":["praxikon:eu:ai-act:actor:gpai-model-provider"],"affected_actor_ids":[],"oversight_actor_ids":["praxikon:eu:ai-act:actor:ai-office"],"evidence_owner_ids":["praxikon:eu:ai-act:actor:gpai-model-provider"],"duty_holder_uncertainty_status":null,"interpretation_status":"settled","interpretation_note":null,"obligation_ids":[],"change_ids":["praxikon:eu:ai-act:change:2026-08-02-gpai-enforcement","praxikon:eu:ai-act:change:2027-08-02-legacy-gpai-models-comply"],"action_ids":["praxikon:eu:ai-act:action:notify-systemic-risk-threshold","praxikon:eu:ai-act:action:request-systemic-risk-reassessment"],"evidence_ids":["praxikon:eu:ai-act:evidence:systemic-risk-notification-file"],"control_ids":["praxikon:eu:ai-act:control:systemic-risk-notification-deadline"],"template_ids":["praxikon:eu:ai-act:template:article-52-legal-text"],"conditions":[{"id":"article-52-notification-trigger","operator":"all","description":"Applies to the provider of a general-purpose AI model as soon as that model meets the condition in Article 51(1), point (a): high impact capabilities, which under Article 51(2) are presumed where the cumulative amount of computation used for its training, measured in floating point operations, is greater than 10^25. The two-week period runs from the moment that requirement is met or it becomes known that it will be met. The second route to systemic risk, a Commission designation under Article 51(1), point (b), or Article 52(4), is not covered here: Article 52(1) refers only to point (a)."}],"exceptions":[{"id":"article-52-legacy-models-transitional","operator":"not","description":"For general-purpose AI models placed on the market before 2 August 2025, Article 111(3) provides that the provider shall take the necessary steps to comply with the obligations of this Regulation by 2 August 2027. For those models the governing date is therefore 2 August 2027 and not the two-week period."}],"statements":[{"kind":"official_fact","text":"Article 51(1), point (a), classifies a general-purpose AI model as a model with systemic risk where it has high impact capabilities evaluated on the basis of appropriate technical tools and methodologies, including indicators and benchmarks; Article 51(2) provides that a model is presumed to have such capabilities where the cumulative amount of computation used for its training, measured in floating point operations, is greater than 10^25. Article 51(1), point (b), reads in full: based on a decision of the Commission, ex officio or following a qualified alert from the scientific panel, it has capabilities or an impact equivalent to those set out in point (a) having regard to the criteria set out in Annex XIII. The requirement of equivalent capabilities or impact and the anchoring in Annex XIII are therefore part of the norm and not only of the procedure. Article 51(3) provides in addition: the Commission shall adopt delegated acts in accordance with Article 97 to amend the thresholds listed in paragraphs 1 and 2 of this Article, as well as to supplement benchmarks and indicators in light of evolving technological developments, such as algorithmic improvements or increased hardware efficiency, when necessary, for these thresholds to reflect the state of the art. The 10^25 threshold above is therefore movable; as long as that act does not exist, the threshold applies as it stands in paragraph 2. See data/ai-act/delegated-acts.json, key praxikon:eu:ai-act:delegated-act:article-51-3-thresholds. Article 52(1) refers only to point (a) and provides that the relevant provider shall notify the Commission without delay and in any event within two weeks after that requirement is met or it becomes known that it will be met, and that the notification shall include the information necessary to demonstrate that the relevant requirement has been met. If the Commission becomes aware of a general-purpose AI model presenting systemic risks of which it has not been notified, it may decide to designate it as a model with systemic risk. Paragraph 2 allows the provider to present, with its notification, sufficiently substantiated arguments to demonstrate that, exceptionally, although the model meets that requirement, it does not present systemic risks due to its specific characteristics and should therefore not be classified as a general-purpose AI model with systemic risk. Paragraph 3 provides that where the Commission concludes that those arguments are not sufficiently substantiated and the provider was not able to demonstrate that the model does not present systemic risks due to its specific characteristics, it shall reject those arguments and the model shall be considered to be a general-purpose AI model with systemic risk. Paragraph 4 empowers the Commission to designate a model as presenting systemic risks, ex officio or following a qualified alert from the scientific panel pursuant to Article 90(1), point (a), on the basis of the criteria set out in Annex XIII, and empowers it to adopt delegated acts in accordance with Article 97 to amend Annex XIII by specifying and updating the criteria set out in that Annex. Paragraph 5 provides that upon a reasoned request of a provider whose model has been designated pursuant to paragraph 4, the Commission shall take the request into account and may decide to reassess whether the model can still be considered to present systemic risks on the basis of the criteria set out in Annex XIII, that such a request shall contain objective, detailed and new reasons that have arisen since the designation decision, that providers may request reassessment at the earliest six months after the designation decision, and that where the Commission decides to maintain the designation a further six months must pass. Paragraph 6 provides that the Commission shall ensure that a list of general-purpose AI models with systemic risk is published and kept up to date, without prejudice to the need to observe and protect intellectual property rights and confidential business information or trade secrets in accordance with Union and national law.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 52(1)-(6) with Article 51(1)-(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"Recital 111 states that the cumulative amount of computation used for training includes the computation used across the activities and methods that are intended to enhance the capabilities of the model prior to deployment, such as pre-training, synthetic data generation and fine-tuning. Recital 112 states that the provider should notify the AI Office at the latest two weeks after the requirements are met or it becomes known that a model will meet the requirements that lead to the presumption, and that this is especially relevant in relation to the threshold of floating point operations because training takes considerable planning which includes the upfront allocation of compute resources and, therefore, providers are able to know if their model would meet the threshold before the training is completed. The same recital states that in the context of that notification the provider should be able to demonstrate that the model exceptionally does not present systemic risks, that the information allows the AI Office to anticipate the placing on the market of models with systemic risks, and that it is especially important for models planned to be released as open-source. Recital 113 states that the Commission should be empowered to designate a model where it becomes aware that the model meets the requirements which previously had either not been known or of which the provider failed to notify it, and that a system of qualified alerts from the scientific panel should exist in addition to the monitoring activities of the AI Office.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Recitals 111 to 113","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"Article 111(3) provides that providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 111(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"The Commission guidelines of 18 July 2025 (C(2025) 5045 final) state in point (63) that a downstream modifier is considered to be the provider of the modified model where the training compute used for the modification is greater than a third of the training compute of the original model, and in point (64) that where the downstream modifier cannot know and cannot estimate the original value, that threshold is replaced by a third of 10^25 FLOP where the original model is a model with systemic risk and otherwise by a third of 10^23 FLOP. Point (70) states that where a downstream actor modifies a model classified as having systemic risk in such a way that they become the provider of the modified model, the resulting model is presumed to have high-impact capabilities, and point (71) states that the modifier must then comply with the obligations for providers of models with systemic risk and notify the Commission in line with Article 52(1). The guidelines are not binding.","citations":[{"source_id":"praxikon:eu:ai-act:source:commission-gpai-guidelines","source_locator":"Commission Guidelines C(2025) 5045 final, 18.7.2025, Section 3.2 points (60) to (67) and Sections 3.2.1 and 3.2.2, points (68) to (71)","source_url":"https://digital-strategy.ec.europa.eu/en/policies/guidelines-gpai-providers","eli":null}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"official_fact","text":"The Commission enforcement powers for general-purpose AI models and the fine regime of Article 101 have been active since 2 August 2026. Article 101(1) provides that the Commission may impose on providers of general-purpose AI models fines not exceeding 3 percent of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000, whichever is higher, where it finds that the provider intentionally or negligently infringed the relevant provisions of the Regulation.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Articles 91-93, 101 and 113","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"}},{"kind":"editorial_interpretation","text":"This is the only duty in this chapter with a numbered deadline, and two weeks is short. Other duties are also tied to a clock, only without a figure: Article 55(1), point (c), requires serious incidents to be reported to the AI Office without undue delay. The question here is therefore not whether you can notify, but whether you see the threshold being crossed in time. Recital 112 leaves little room to push that back: the legislator expressly assumes that the upfront allocation of compute lets you know before training ends that you will meet the threshold. The remaining edge question is how firm that knowledge is for a run not yet allocated, and it is small next to the duty itself. Four things are missed in practice. The first is the transitional rule: if your model was already on the market before 2 August 2025, Article 111(3) gives you until 2 August 2027, and that is the difference between two weeks and two years. The second is the reach of the trigger: only the threshold route of Article 51(1), point (a), starts this clock. If your model is designated by the Commission under Article 51(1), point (b), or Article 52(4), Article 55 begins without Article 52 asking anything of you. The third is the reversal in the last sentence of paragraph 1: if the Commission becomes aware of a model it was not notified about, it may designate it, and you then hold the conversation from a designation rather than from your own file. Since 2 August 2026 the Article 101 fine regime stands behind that. The fourth is the rebuttal route in paragraph 2: those arguments belong with the notification and not after it, so they must already be ready at the moment you notify. Once designated, only paragraph 5 remains, and that route is slow: six months after the decision at the earliest, and only with objective, detailed and new reasons that have arisen since it. The text names the Commission as addressee; recital 112 and Article 55(1), point (c), name the AI Office, which performs this task within the Commission. For an organisation that merely uses an external model this article does not bite: it addresses the provider of the model. That does not put further development out of reach: under point (71) of guidelines C(2025) 5045 final, a party that becomes the provider of a systemic-risk model through a modification must notify the Commission in line with Article 52(1).","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 52(1)-(6) with Article 51(1)-(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Recitals 111 to 113","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 111(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"source_id":"praxikon:eu:ai-act:source:commission-gpai-guidelines","source_locator":"Commission Guidelines C(2025) 5045 final, 18.7.2025, Section 3.2 points (60) to (67) and Sections 3.2.1 and 3.2.2, points (68) to (71)","source_url":"https://digital-strategy.ec.europa.eu/en/policies/guidelines-gpai-providers","eli":null}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"editorial"}},{"kind":"recommended_action","text":"First establish whether you are the provider of the model and not merely a user, and whether your model was already on the market before 2 August 2025, because the date in Article 111(3) then applies instead of the two-week period. If you are the provider of a new model, record the planned and the consumed training compute per training run, including pre-training, synthetic data generation and fine-tuning, because recital 111 counts all three. Agree who notifies once the threshold comes into view, so the two-week period is not spent finding an owner, and tie that to the moment compute is allocated rather than to the end of the run. Keep the reasoning with which you would argue that the model does not present systemic risks ready before you notify, because it belongs with the notification. If you have already been designated under paragraph 4, build deliberately towards objective, detailed and new reasons that have arisen since the designation decision, because only those get you to a reassessment after six months. Retain the notification, the substantiation sent with it, any reassessment request and the Commission response as a living file per model version.","citations":[{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 52(1)-(6) with Article 51(1)-(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Recitals 111 to 113","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 111(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"editorial"}}],"legal_status":"applicable","deadline_at":"2025-08-02T00:00:00.000Z","timing_basis":null,"high_risk_regime_from":null,"links":[{"relation":"public_page","href":"https://www.praxikon.com/en/verplichtingen/article-52-systemic-risk-classification","label":"Open the human explanation"},{"relation":"official_source","href":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","label":"Article 52 on EUR-Lex"},{"relation":"related","href":"https://digital-strategy.ec.europa.eu/en/policies/guidelines-gpai-providers","label":"Guidelines C(2025) 5045 final on the scope of the GPAI obligations"}],"review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"source_review":{"level":"source_verified","last_checked_at":"2026-08-14T00:00:00.000Z","next_review_due_at":"2027-02-10T00:00:00.000Z","date_basis":"first_publication"}}],"included":{"sources":[{"id":"praxikon:eu:ai-act:source:commission-gpai-guidelines","title":{"nl":"Richtsnoeren voor GPAI-modelaanbieders","en":"Guidelines for GPAI model providers"},"publisher":{"nl":"Europese Commissie","en":"European Commission"},"canonical_url":"https://digital-strategy.ec.europa.eu/en/policies/guidelines-gpai-providers","eli":null,"source_version":"checked-2026-08-08","verified_at":"2026-08-08T00:00:00.000Z","fingerprint_basis":"canonical_url|source_version|verified_at","source_record_hash_sha256":"b3691c417d2ea106c7767e1b78bf30f045b0172a4292cb44ba76ff45109de497","review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"legacy_id":"raip:source:commission-gpai-guidelines"},{"id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","title":{"nl":"EU AI-verordening 2024/1689","en":"EU Artificial Intelligence Act 2024/1689"},"publisher":{"nl":"Europees Parlement en Raad","en":"European Parliament and Council"},"canonical_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj","source_version":"original-oj-2024-07-12","verified_at":"2026-08-08T00:00:00.000Z","fingerprint_basis":"canonical_url|source_version|verified_at","source_record_hash_sha256":"bf0fca3e1fb47ce58924f6e736d572bb5db3812c3276c0b2891fbf328c42a5c6","review":{"reviewed_at":"2026-08-08T00:00:00.000Z","reviewer":"Praxikon release validation","review_method":"source_link_and_rule_validation","legal_status":"source_checked"},"legacy_id":"raip:source:reg-eu-2024-1689"}]},"links":{"self":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-52-systemic-risk-classification&lang=en","alternate":"https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-52-systemic-risk-classification&lang=en&format=jsonld","licence":"https://www.praxikon.com/nl/legal/terms"}}