General-purpose AI models and their EU representative

Obligations for all GPAI model providers (Article 53)

• Draw up and keep up to date technical documentation of the model, including training and testing, for the AI Office and national authorities
• Provide information and documentation to downstream providers that integrate the model into their AI systems
• Put in place a policy to comply with EU copyright law, including rights reservations
• Publish a sufficiently detailed summary of the content used for training, using the AI Office template

Providers of models released under a free and open-source licence are exempt from the first two and from Article 54, unless the model presents systemic risk.

Models with systemic risk (Articles 51 and 55)

A model is presumed to have high-impact capabilities when the cumulative compute used for training exceeds 10^25 floating-point operations. Providers of such models must also perform model evaluations including adversarial testing, assess and mitigate systemic risks, report serious incidents to the AI Office, and ensure adequate cybersecurity.

Timing

The General-Purpose AI Code of Practice can be used to demonstrate compliance. Under Regulation (EU) 2026/1744, the AI Office also has exclusive competence over AI systems built on a GPAI model by the same provider or group, with exceptions such as AI in Annex I products (Article 75(1)).

Frequently asked questions

Do non-EU GPAI model providers need an EU representative?

Yes. Before placing a general-purpose AI model on the EU market, a provider established in a third country must appoint an authorised representative in the Union by written mandate (Article 54), unless an open-source exemption applies.

When is a GPAI model considered to have systemic risk?

It is presumed when training compute exceeds 10^25 floating-point operations, or the Commission designates it based on the criteria in Annex XIII.

Is the Article 54 representative the same as the Article 22 representative?

No. Article 54 covers general-purpose AI models and cooperation with the AI Office; Article 22 covers high-risk AI systems. One company can hold both mandates, but they are separate.

Related

Note: This guide provides general information about Regulation (EU) 2024/1689 (AI Act) as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI), not legal advice. Last reviewed 5 October 2026.