General-purpose AI (GPAI) models and systems are subject to a tailored and tiered regulatory framework under the AI Act.
GPAI models are defined functionally (e.g. generality in the performance of tasks) and are typically integrated into GPAI systems.
The European Commission, through its AI Office, has sweeping powers to enforce the provisions applicable to GPAI models and systems. These provisions will apply from 2 August 2025 (see also AI Act Timeline).
The AI Office is facilitating the drawing-up of a code of practice on GPAI models by independent experts. The code is expected to set out "commitments to which providers [of GPAI models] may adhere to ensure compliance with their obligations under the AI Act.”
In parallel, the EU executive body opened a consultation until 22 May 2025 in preparation for its upcoming non-binding guidelines, which will aim to clarify the obligations of providers GPAI models.
This cheat sheet by Cullen International provides a summary of the core provisions on GPAI models under the AI Act:
Clients of our European Digital Economy service, can access it directly on our client portal via the following link:
more news
12 May 25
Global trends in AI regulation
Our latest Global Trends benchmark compares policies and regulations on artificial intelligence (AI) across 14 jurisdictions around the world.
08 May 25
Patchwork approach to 2G/3G switch-off poses challenge for IoT providers
Our IoT regulatory intelligence service provides a clear and comprehensive benchmark tracking the switch-off status of 2G and 3G networks in 66 countries across the world.
05 May 25
National measures against spoofing practices in Europe
Cullen International’s research shows recent developments in national regulation against spoofing practices across Europe.