What applies
Since 2 August 2025, the duties for providers of general-purpose AI (GPAI) models have applied — the model-provider layer, companies like OpenAI, Google, or Anthropic: technical documentation, a copyright policy, transparency about training data.
For most companies that doesn't mean “not my problem” — it means “my supply chain's problem.” Anyone building or buying AI products on top of such models should check whether the provider delivers what the Regulation requires, because your own duties are built on that foundation.
Who it affects
Directly: providers of large AI models. Indirectly: everyone building products on those models, or relying on them for business-critical work.
Example (fictional): The start-up on thin ground
A software start-up builds a contract-analysis assistant on a smaller, cheaper language model from a third country. A large corporate customer demands the model provider's GPAI documentation during procurement — training-data transparency, copyright policy.
The model provider delivers none of it. The start-up can't close the gap and drops out of the vendor shortlist — a competitor with a documented, EU-aligned model wins the deal.
The risks, plainly stated
Fines for model providers
Up to €15 million or 3% of worldwide annual turnover for GPAI providers that breach their duties (Art. 101 AI Act).
Supply-chain risk
If your product is built on a non-aligned model, you inherit the problem — up to a forced model switch mid-operation.
Exclusion from tenders
Large enterprises and public buyers now ask about model compliance during procurement — no answer, no shortlist.
Your next steps
- 01Take inventory of which of your products and tools rely on which models
- 02Request and file the GPAI documentation from your model providers
- 03Define a fallback model for the case where a provider doesn't deliver
In Compliverse
The compass turns exactly these steps into measures in your plan automatically — with deadlines, owners, and evidence.
Plain-language product content, not legal advice · Case studies are fictional · Fine amounts as stated in the legal act (“up to”)