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GPAI Checker — Does Your AI Model Have EU AI Act GPAI Obligations?

Updated · Indicative — not legal advice

Check whether your AI model qualifies as GPAI under the EU AI Act and which obligations apply: standard (all providers), systemic risk (>10²⁵ FLOPs), or reduced (open-source weights). Results in 2 minutes.

What qualifies as a GPAI model under the EU AI Act?

A General-Purpose AI (GPAI) model under Art. 3(63) is an AI model that:

Examples include large language models (LLMs), large multimodal models, and large code-generation models. A downstream application built on top of a GPAI model is a GPAI system — different obligations apply to the model provider vs. the downstream integrator.

GPAI obligations have been in effect since 2 August 2025.

The three GPAI obligation tiers

Tier Trigger Key obligations
Reduced Open-source weights publicly released Copyright compliance; cooperation with AI Office; systemic risk obligations if threshold exceeded
Standard All non-open-source GPAI providers Technical documentation (Art. 53); copyright summary; downstream support; AI Office cooperation
Systemic risk Training compute > 10²⁵ FLOPs All standard obligations + adversarial testing, incident reporting, cybersecurity measures, energy consumption disclosure

Which tier applies to you?

Question 1: Do you publicly release model weights so anyone can run the model locally?

Question 2: Was your model trained with more than 10²⁵ floating-point operations (FLOPs)?

For the full list of GPAI obligations and how to meet them, see the GPAI obligations guide →

Frequently Asked Questions

Models trained with more than 10²⁵ floating-point operations (FLOPs) are presumed to present systemic risk under Art. 51(2). This threshold captures the largest frontier models. The European Commission can update this threshold via delegated acts. If uncertain about your compute, use conservative estimates — if in doubt, assume systemic risk obligations apply.

No. Open-source GPAI models (publicly released weights) are exempt from the technical documentation and copyright summary obligations. They are NOT exempt from: copyright law compliance, cooperation with the AI Office on investigations, and — if they present systemic risk — all systemic risk obligations (adversarial testing, incident reporting, cybersecurity, energy reporting).

The EU AI Office (under the European Commission) is the primary regulator for GPAI models across the EU. National competent authorities handle downstream deployers and non-GPAI systems.

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