Praxikon

Q&A

Guidelines on obligations for General-Purpose AI providers - Questions & Answers

PublishedEuropean Commission, DG CONNECT11 Nov 2025

Q&A on the guidelines for providers of general-purpose AI models. The document makes concrete the indicative computational threshold of 10^23 FLOP as a starting point for the question of whether something is a general-purpose AI model, with the nuance that a model above that threshold might nevertheless fall outside the definition if it lacks genuine generality. It further explains when a party that adapts an existing model itself becomes a provider, with the rule of thumb that more than one third of the original training computational capacity is used. The scope of the open-source exception is also defined. The date 11 November 2025 appears as last updated at the bottom of the page.

What this means for you

This is the source that determines whether a Dutch party that fine-tunes models falls within the role of provider with a complete separate set of obligations.