Policy Brief- Guidelines on the scope of the obligations for general-purpose AI models established by the AI Act
The new Policy Brief curated by the law firm Oreste Pollicino & Partners is now available online. It focuses on the European Commission’s Guidelines regarding the obligations for General-Purpose AI Models (GPAIMs) introduced by the new AI Act (Regulation (EU) 2024/1689).
Published on July 18, 2025, these guidelines clarify the specific requirements for GPAIM providers, with a focus on:
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Technical criteria and computational thresholds for defining a GPAIM;
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Responsibilities throughout the entire model lifecycle, from pre-production to decommissioning;
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Criteria for systemic risk classification;
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Exemptions for open-source models;
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The role of the voluntary Code of Conduct as a pathway to early compliance.
The Policy Brief offers a concise yet thorough overview of the key developments, useful for companies, developers, researchers, and policymakers looking to navigate the new European regulatory landscape.
Download the full document here: POLICY-BRIEF_GPAI_Rev.pdf
Please note that the provisions will enter into force on August 2, 2025, while actual enforcement by the Commission will begin in August 2026. It is therefore essential to prepare in advance.