Article 88 of Regulation (EU) 2024/1689 — Enforcement of the obligations of GPAI providers. Official text, practical interpretation, key obligations and compliance implications.
Article 88 settles who polices general-purpose AI models: the Commission, exclusively, acting through the AI Office. National authorities supervise AI systems; for the models underneath them, enforcement is centralised in Brussels.
Official Text Summary
The Commission has exclusive powers to supervise and enforce Chapter V of the Regulation — the obligations of providers of general-purpose AI models — and entrusts the implementation of those tasks to the AI Office, without prejudice to the Commission's organisational powers and the Member States' competences. National market surveillance authorities keep their full mandate over AI systems, including systems built on GPAI models; where they need action at model level for the performance of their own tasks, they may request the Commission to exercise its powers. The split is deliberate: systems are supervised where they are deployed, models are supervised once for the whole Union.
Key Obligations
- The Commission has exclusive powers to supervise and enforce Chapter V — the GPAI obligations — and entrusts their implementation to the AI Office
- National market surveillance authorities may ask the Commission to exercise these powers where needed for their own tasks
- Centralisation prevents 27 divergent readings of the same frontier model's obligations
Compliance Timeline
Applies from 2 August 2026; the 2026 Digital Omnibus deferred the substantive high-risk obligations (Annex III to 2 December 2027, Annex I to 2 August 2028) but did not move this provision.
Official AI Act Compliance Deadline Calendar
Updated · Sources: Regulation (EU) 2024/1689 and the 2026 Digital Omnibus on AI.
| Obligation | Applies to | Original date | New date | Status | Countdown | Legal basis |
|---|---|---|---|---|---|---|
| Prohibited Practices (Art. 5) | All providers and deployers | active | — | AI Act Art. 5 | ||
| GPAI Rules (Chapter 5) | GPAI model providers | active | — | AI Act Art. 51-56 | ||
| Commission Enforcement Powers over GPAI | GPAI model providers | active | — | AI Act Art. 88-94, 101 | ||
| Transparency Obligations (Art. 50) | Providers and deployers of chatbots, generative, emotion recognition systems | active | — | AI Act Art. 50 | ||
| New Art. 5 Prohibition (CSAM / non-consensual intimate imagery) | Providers and deployers of generative AI systems | active | — | AI Omnibus 2026 Art. 5 | ||
| AI-Generated Content Marking (pre-existing systems) | Providers of generative AI systems on the market before 2 Aug 2026 | active | — | AI Act Art. 50(2) — transitional | ||
| Regulatory Sandboxes | National competent authorities | deferred | — | AI Omnibus 2026 Art. 57 | ||
| High-risk AI — Annex III (standalone) | Providers of standalone Annex III systems | deferred | — | AI Omnibus 2026 Art. 6(2) | ||
| High-risk AI — Annex I (embedded) | AI embedded in Annex I regulated products | deferred | — | AI Omnibus 2026 Art. 6(1) |
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AI Act meets DORA and NIS2
Is your organisation subject to both the AI Act and DORA? The two regulations intersect on the operational resilience of financial AI systems. Our sister site regulation-dora.eu covers DORA in depth — including what the AI Act adds on top of an existing DORA programme.
The AI Act for financial institutions ↗ Explore regulation-dora.eu ↗Frequently Asked Questions
A frontier model is placed on the market once and consumed everywhere; 27 parallel enforcement tracks would produce contradictory obligations for the same artefact. Centralising in the AI Office gives providers a single counterpart and the market a single interpretation.
Two regulators instead of one: your national market surveillance authority for the AI system you ship, the Commission for the model underneath. If a model-level defect surfaces through your system, expect the national authority to route it upward under Article 88(2).
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