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Direct answer

What does a provider of a GPAI model actually have to do under the AI Act?

6 obligations under the AI Act bear on this, of which 6 apply today.

First step: Record per requirement which standard or specification you rely on, and justify every departure.

The 6 obligations for a provider of a GPAI model produce 3 concrete actions. Each action below belongs to a provision, carries its own conditions and names the date by which it has to be done. Likely role: provider of a gpai model.

The conclusion and your first steps

This applies now

What you have to do

  1. Record per requirement which standard or specification you rely on, and justify every departure. Keep a coverage matrix of the requirements of Section 2 against the harmonised standards, common specifications and own documents applied, noting per row the publication status in the Official Journal, and write out the Article 41(5) justification for every common specification you do not apply.
  2. Justify and record your reliance on Article 4a. Only for those who themselves decide to process special categories of personal data for bias testing. In that case record which paragraph of Article 4a you rely on and whether that paragraph is open to your role, why other data do not suffice, which safeguards apply, who has access and when the data are deleted. Replace old references to Article 10(5) while you are there.
  3. Notify the Commission within two weeks. Notify the model as soon as it meets the condition in Article 51(1), point (a), or as soon as it becomes known that it will, with the information necessary to demonstrate that the requirement has been met, and with any substantiation that the model does not present systemic risks after all.
Read the official sourceChecked on

General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.

Full map for your situation

Source and locator

Every statement above rests on these texts. The locator points to the place in the text, the version and the date say which edition was checked.

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council, version original-oj-2024-07-12, checked on , ELI http://data.europa.eu/eli/reg/2024/1689/oj

    Locators in this source

    • Article 40(1) to (3)
    • Article 41(1) to (3)
    • Article 41(4), (5) and (6)
    • Article 42(1) and (2)
    • Article 10(4); Article 15; Article 43(1); Chapter III, Section 5, and Article 113, second paragraph
    • Article 52(1)-(6) with Article 51(1)-(3)
    • Recitals 111 to 113
    • Article 111(3)
    • Articles 91-93, 101 and 113
    • Article 53(1), Annex XI and Annex XII
    • Article 113(3)(b)
    • Article 53 and Annexes XI-XII
    • Article 54(1)-(6)
    • Article 3(5)
    • Article 101(1)-(6)
    • Article 55(1)-(2) with Article 51 and Article 52
  • Digital Omnibus on AI 2026/1744

    European Parliament and Council, version official-journal-2026-07-24, checked on , ELI http://data.europa.eu/eli/reg/2026/1744/oj

    Locators in this source

    • Article 1, points (17) and (18), amending Article 40(2) and Article 42
    • Article 1, point 6, inserting Article 4a: Article 4a(1), points (a) to (f), and Article 4a(2), points (a) and (b)
    • Article 1, point 6 (insertion) and point 9 (Article 10 amended, paragraph 5 deleted)
    • Article 1, point 2(b), replacing Article 2(7)
    • Recital 9, Article 4 (entry into force) and Article 1, point 40(a), replacing Article 113, third paragraph, point (a)
    • Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)
  • Guidelines for GPAI model providers

    European Commission, version checked-2026-08-08, checked on

    Locators in this source

    • 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)
    • Scope and provider qualification guidance
  • CEN-CENELEC JTC 21: European standards under standardisation request M/613

    CEN-CENELEC JTC 21, version work-programme-checked-2026-08-08, checked on

    Locators in this source

    • EN 18286:2026, CEN/CLC/JTC 21 under standardisation request M/613
    • prEN 18228 (draft standard), CEN/CLC/JTC 21 under M/613

Dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0, schema 1.5.0.

Execution

Implement the GPAI provider obligations for each model

As a GPAI model provider, you organise technical documentation, information for downstream providers and a copyright policy, among other duties. Models with systemic risk have additional obligations. Embed AI helps record the role, applicability, governance and evidence for each model. The source interpretation above is separate from this commercial referral by Praxikon to an affiliated brand.

See the GPAI governance approach
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Zahed Ashkara, jurist and freelance AI & Privacy Consultant

Behind this page

Zahed Ashkara

Freelance AI & Privacy Consultant, jurist