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:
- Is trained on large amounts of data using self-supervision at scale
- Displays significant generality
- Is capable of competently performing a wide range of distinct tasks
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?
- Yes → Reduced obligations (but read the systemic risk question below)
- No → Standard obligations minimum
Question 2: Was your model trained with more than 10²⁵ floating-point operations (FLOPs)?
- Yes → Systemic risk obligations apply (in addition to reduced or standard)
- No / unknown → Use conservative estimates; if uncertain at scale, consult with technical advisors
For the full list of GPAI obligations and how to meet them, see the GPAI obligations guide →
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.
Explore regulation-dora.eu ↗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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