Article 55: GPAI models with systemic risk
Additional duties for the most capable general-purpose AI models, on top of Article 53.
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 GPAI model has high-impact capabilities, presumed above 10^25 FLOPs of cumulative training compute, or is designated by the Commission.
What the official source establishes
Article 55 obliges providers of GPAI models with systemic risk to perform model evaluations including adversarial testing, assess and mitigate systemic risks at Union level, track and report serious incidents, and ensure adequate cybersecurity of model and infrastructure. The duties apply since 2 August 2025; AI Office enforcement is active since 2 August 2026.
Our interpretation
The 10^25 FLOPs threshold is a presumption, not a shield: the Commission can also designate models on capabilities, and fine-tuning on top of an existing model can in some circumstances trigger a qualification of its own.
What you can do now
Model providers near the threshold: set up compute monitoring now and join the Code of Practice to carry the burden of proof.
- 01
Perform model evaluations and risk mitigation
Evaluate the model including adversarial testing, assess and mitigate systemic risks, report serious incidents and secure the model.
What to retain
Systemic-risk file
Evaluation results, risk assessments, mitigations, incident reports and security measures per model version.
Control and reassessment
Compute threshold monitoring
Monitor cumulative training compute and notify the Commission when the threshold is reached.
Public tools
Full text of Article 55
The full legal text in the public AI Act Explorer.
Conditions and exceptions
- The GPAI Code of Practice can, following the adequacy assessment, serve as a means to demonstrate compliance.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 55(1)-(2) with Article 51 and Article 52
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.
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.
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).
Version history
v1.0.0
2 August 2025
Article 55: GPAI models with systemic risk
Additional duties for the most capable general-purpose AI models, on top of Article 53.
Execution
From obligation to arranged and demonstrable
Knowing where you stand is step one. Embed AI translates this obligation into a concrete approach for your organisation: scope, ownership, register and evidence.
See the Embed AI approachFor AI agents and integrations
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