Article 53: GPAI model providers
Documentation, information, copyright and transparency duties for providers of general-purpose AI models.
The official source remains authoritative. This general interpretation is not legal advice.
- Status
- Applicable
- Application date
- 2 August 2025
- Version
- 1.0.0
- Last reviewed
- 8 August 2026
Who this is relevant to
When this applies
Provider of a GPAI model
A party that places a general-purpose AI model on the Union market.
- 1The party is a provider of a GPAI model placed on the Union market.
- 2For models placed on the market from 2 August 2025, the duties apply from that time. Models placed on the market before 2 August 2025 must comply by 2 August 2027.
What the official source establishes
Article 53 applies since 2 August 2025 to new GPAI models. Providers maintain technical documentation, provide information to downstream providers, operate a Union copyright policy and publish a sufficiently detailed summary of training content.
Providers of GPAI models placed on the market before 2 August 2025 must comply with the applicable obligations by 2 August 2027.
Our interpretation
An organisation merely using an external GPAI model does not thereby automatically become a GPAI model provider. First determine its role in the value chain.
What you can do now
Record model versions, role qualification, documentation owners, downstream information, copyright policy and training summary in one change-controlled file.
- 01
Maintain GPAI documentation and transparency information
Maintain technical documentation, information for downstream providers, a copyright policy and a public summary of training content.
What to retain
GPAI compliance file
Current technical documentation, downstream information, copyright policy and public training summary.
Control and reassessment
GPAI documentation change control
Update documentation and downstream information when the model, capabilities or risks change.
Public tools
GPAI obligations route
Public guide to GPAI model obligations and exceptions.
Conditions and exceptions
- The open-source exception is limited and retains, among other things, the copyright policy and public training-content summary. Additional duties apply to models with systemic risk.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 53(1), Annex XI and Annex XII
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 113(3)(b)
Guidelines for GPAI model providers
European Commission | checked-2026-08-08
Source locator: Scope and provider qualification guidance
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 53 and Annexes XI-XII
What changed in this
Moments when this obligation took effect, moved or received official guidance.
2027-08-02 | upcoming
Legacy GPAI models must comply
Models placed on the market before 2 August 2025 have until 2 August 2027.
2026-08-02 | applicable
GPAI enforcement powers active
Since 2 August 2026 the Commission can request GPAI information, conduct evaluations and require measures.
2025-08-02 | applicable
GPAI model obligations apply
Since 2 August 2025 the obligations for providers of general-purpose AI models apply.
2025-07-18 | guidance
Guidelines on the scope of the GPAI obligations
The Commission explains when someone becomes the provider of a GPAI model, including through fine-tuning.
2025-07-10 | guidance
General-Purpose AI Code of Practice published
The voluntary code of practice gives GPAI model providers a route to demonstrate compliance.
What member states are doing with this
Dated signals from the enforcement tracker that refer to this obligation.
EU | 2026-08-02 | Europese Commissie / AI Office
GPAI and Article 50 enforcement powers active
Since 2 August 2026 the European Commission, through the AI Office, can enforce the GPAI obligations and national authorities are competent to enforce the Article 50 transparency obligations. Most other AI Act obligations also apply from this date.
EU | 2025-07-18 | Europese Commissie / AI Office
Guidelines for providers of general-purpose AI models
The Commission publishes guidelines clarifying who qualifies as a provider of a general-purpose AI model, when a model poses systemic risk and how the AI Office will apply the GPAI obligations, including exemptions for certain open-source models. Together with the GPAI Code of Practice, these guidelines form the enforcement framework the AI Office relies on since 2 August 2026.
EU | 2025-07-10 | Europese Commissie / AI Office
GPAI Code of Practice published
The AI Office publishes the final Code of Practice for providers of general-purpose AI models, with chapters on transparency, copyright and safety and security. The Commission and the AI Board subsequently assess the code as an adequate voluntary tool to demonstrate compliance with the GPAI obligations. 21 organisations sign the full code, including Amazon, Anthropic, Google, IBM, Microsoft, OpenAI and Mistral AI; xAI signs only the safety and security chapter and must demonstrate compliance with the transparency and copyright obligations via alternative means. It is followed shortly by the guidelines on the scope of GPAI obligations (18 July 2025) and the training-data summary template (24 July 2025).
Italy | 2024-12-20 | Garante per la protezione dei dati personali
Italian authority fines OpenAI 15 million euros
The Garante closed its ChatGPT investigation with a 15 million euro fine for training on personal data without an appropriate legal basis and inadequate information. The Court of Rome annulled the fine on 18 March 2026: after OpenAI established itself in Ireland, jurisdiction ran through the one-stop-shop mechanism, and the court never reached the substantive allegations. Since 2 August 2025, GPAI models carry their own documentation and transparency duties under the AI Act, enforced by the AI Office rather than national privacy authorities.
Garante, besluit 2 november 2024, bekendgemaakt 20 december 2024
Version history
v1.0.0
2 August 2025
Article 53: GPAI model providers
Documentation, information, copyright and transparency duties for providers of general-purpose AI models.
Execution
Hold your model supplier to the information duty
GPAI enforcement is active. Embed AI helps you request the right transparency information from suppliers and process it into your file.
See the Embed AI approachFor AI agents and integrations
This page and the machine output derive from the same versioned object. Use the API for deterministic filters by role, topic and time.