Direct answer
What obligations does the provider of a GPAI model have under Article 52 of the AI Act?
Article 52 of the AI Act covers notification of a GPAI model with systemic risk. 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. The duty sits with the provider of a GPAI model. This obligation has applied since 2 August 2025.
Your question is about Article 52: notification of a GPAI model with systemic risk. That obligation applies today. Whether your system actually falls under it depends on conditions you assess yourself.
You determine this yourself
- 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).
- 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.
First step: Notify the Commission within two weeks.
This applies now
Your first actions
- 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.
Record this
- Systemic-risk notification file
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
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