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The EU AI Act assigns responsibilities at different layers: to providers of general-purpose AI (GPAI) models, to providers of AI systems that use those models, and to organizations that deploy AI systems. These roles can overlap within one organization, but using a GPAI model does not by itself make a downstream organization its model provider. GPAI provider obligations began applying on 2 August 2025, according to the European Commission. The specific duties for a downstream organization depend on its role and the system involved; the full Article 25 provider-reclassification test and Article 26 deployer-duty list should be checked in the current consolidated Act before making a case-specific determination.
What is the difference between a GPAI model provider and an AI-system deployer?
A GPAI model provider has duties concerning the model itself. An AI-system provider has duties concerning an AI system it develops, places on the market or puts into service, while a deployer uses an AI system under the Act’s deployer role. The role labels describe different legal relationships; they do not, on their own, determine every duty that applies.
The same organization can occupy more than one role. For example, an organization that provides a GPAI model and also integrates it into an AI system may have model-provider duties and the system-provider duties applicable to that system. A downstream organization that integrates someone else’s model may separately be the AI-system provider, while the model provider remains responsible for its own model-level obligations.
The useful starting point is therefore not simply “Who uses AI?” but “Which layer does this activity concern, and what role does this organization have at that layer?” A company can supply a model without deploying the finished system; another company can integrate that model and provide the resulting system; and an organization using the system can have a deployer role. Those possibilities should be analyzed separately rather than collapsed into a single label.
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| Question | GPAI model provider | AI-system provider or deployer |
|---|---|---|
| What is regulated? | The model: documentation, information for downstream system providers, copyright policy and a public training-content summary; additional duties apply to systemic-risk models. | The AI system and/or its use. Which duties apply depends on the system’s status and whether the organization is its provider or deployer. |
| Who receives or carries the duties? | The model provider. Documentation is prepared for authorities, and specified information is made available to AI-system providers intending to integrate the model. | The organization that acts as the system provider or deployer, as applicable. |
| Where can roles overlap? | A model provider that also integrates its model into an AI system may have system-provider duties too. | A downstream system provider has separate duties; the model provider must cooperate and provide relevant information. |
| What can be stated here? | The Article 53 baseline and Article 55 systemic-risk duties are described below. | The European Commission provides a provider definition and Article 50 transparency framing. The complete Article 25 and Article 26 analyses require checking the operative provisions. |
What obligations apply to general-purpose AI model providers?
Article 53 establishes a baseline for GPAI model providers. In the Commission’s account, these obligations entered into application on 2 August 2025. They cover documentation, downstream information, copyright compliance, a public summary of training content, and cooperation with authorities.
These requirements are not interchangeable deliverables. Some material is prepared for public authorities, some is made available to system providers intending to integrate the model, and the training-content summary is made public. Keeping the audiences and purposes distinct helps avoid treating one document as a substitute for another.
Maintain documentation for authorities
The provider must draw up and keep current technical documentation about the model. This includes information on training and testing processes and their evaluation results, for the AI Office and national competent authorities. The documentation duty is distinct from the information supplied to downstream system providers: the Act identifies different recipients and purposes.
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Give integrating system providers specified information
A provider must draw up, maintain and make available specified model information and documentation to providers of AI systems that intend to integrate the model. The purpose is to help those system providers understand the model’s capabilities and limitations and meet their own obligations under the Act. This is not a transfer of the downstream provider’s responsibility to the model provider; it is an information and cooperation requirement alongside the downstream provider’s own duties.
This downstream channel is important because a system provider may need information about the model it incorporates to assess the finished system and meet the requirements applicable to that system. The Commission describes cooperation between the model provider and downstream provider as part of the division between model-level and system-level measures. The precise specified contents should be taken from the operative provision and applicable documentation, rather than guessed from a general description.
In practical role mapping, distinguish a provider that intends to integrate a model from an organization that simply encounters or uses a GPAI-powered system. The obligation described here concerns information made available to AI-system providers intending to integrate the model. It does not turn every downstream user into a model provider, nor does it remove the system provider’s own responsibility.
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Providers must put in place a policy to comply with Union copyright and related-rights law. The policy must include identifying and respecting rights reservations under the referenced copyright directive. The obligation concerns the provider’s compliance policy; it should not be confused with the separate obligation to publish a summary of training content.
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The public summary does not replace the policy, and a copyright policy does not replace the summary. They address different requirements: one is a policy for compliance with copyright and related-rights law, including rights reservations, while the other is a publicly available account of training content.
Publish a sufficiently detailed training-content summary
The provider must make publicly available a sufficiently detailed summary of the content used to train the model, using the AI Office template. This public summary is a separate deliverable from confidential or authority-facing technical documentation. The Commission’s description specifies a summary, not a requirement in this material to publish the full technical file.
Because the summary is public and template-based, it should not be confused with the more technical documentation prepared for authorities or the information made available to integrating system providers. Each has a different audience. A provider assessing its compliance should account for all three channels rather than assuming that a document prepared for one recipient automatically satisfies another duty.
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Cooperate with authorities
Providers must cooperate as necessary with the European Commission and national competent authorities. That duty sits alongside the documentation, information, copyright-policy and public-summary requirements; it is not a substitute for any of them.
Does the open-source exception remove all GPAI provider duties?
No. A qualifying free and open-source license may exempt a provider from the two documentation duties in Article 53(1)(a) and (b), but this is not a blanket exemption from Article 53. The exception also does not apply to GPAI models with systemic risk.
The conditions described by the Commission require that model parameters—including weights—architecture information and usage information be publicly available. Providers should verify that the license and public-availability conditions are actually met before relying on the exception. The exemption described here concerns the documentation duties; it does not eliminate the separate copyright-policy, public training-summary or cooperation duties.
That limitation is easy to overlook when “open source” is used as a broad shorthand. The relevant question is whether the specific conditions for the exception are met, including public availability of the listed information, and which exact duties the exception covers. It does not erase the provider’s status or create a general exemption from the regulation. A systemic-risk GPAI model is outside this documentation exception even if the other conditions appear to be satisfied.
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Providers of GPAI models with systemic risk have additional responsibilities under Article 55. These duties focus on evaluation, risk mitigation, serious-incident handling and cybersecurity, and apply in addition to the baseline obligations unless a specific legal exception applies.
- Evaluate the model: use appropriate protocols and tools, including documented adversarial testing.
- Assess and mitigate systemic risks: assess possible systemic risks at Union level and take steps to mitigate them.
- Track and report serious incidents: track, document and report serious incidents and corrective measures without undue delay.
- Protect model and infrastructure: provide adequate cybersecurity protection for the model and its physical infrastructure.
The Commission’s current explanations describe a presumption of systemic risk when training compute exceeds 1025 FLOP, while noting that the threshold is under review. The Commission’s scope guidance also describes GPAI models in its scope explanation as trained above 1023 FLOP and capable of generating language. These are Commission explanations, not timeless shorthand for every legal question: the systemic-risk presumption and the scope description serve different purposes, and the compute threshold is under review.
The two figures should not be treated as interchangeable cutoffs. The above-1023-FLOP figure appears in the Commission’s explanation of GPAI scope together with language-generation capability. The above-1025-FLOP figure is described as a presumption of systemic risk. Neither is an empirical measure of harm or model quality. Since the Commission says the systemic-risk threshold is under review, organizations should check the current Commission explanation and consolidated Act when making a live classification.
How do GPAI model obligations interact with downstream AI-system obligations?
They are complementary rather than interchangeable. The model provider must supply specified information and cooperate so that an AI-system provider can understand the integrated model and meet applicable system-level duties. The downstream provider remains responsible for the duties that apply to its AI system.
The Commission frames the issue as how developers can use GPAI models responsibly and how model-level and system-level measures should be divided. In practice, a downstream organization needs to assess its own role and system rather than assuming that a model provider’s compliance covers the finished system. Conversely, integrating a model does not automatically make every downstream organization a GPAI model provider.
This division answers two common questions at once: what obligations apply to general-purpose AI model providers, and how do those obligations interact with obligations for the system that uses the model? The provider’s Article 53 and, where relevant, Article 55 tasks relate to the model. The AI-system provider must separately identify the system-level requirements that apply to its product or service. Cooperation and information-sharing help connect the layers, but they do not merge them into a single compliance obligation.
When one organization supplies both the model and the system
If a model provider also integrates the model into an AI system, it may be subject to both sets of requirements: model-level duties under the GPAI provisions and whichever AI-system-provider requirements apply to its system. Treating the organization as having only one role can miss duties at the other layer.
A practical review should therefore list the organization’s activities at each layer rather than assign a single company-wide label. For example, the relevant questions can include whether it provides the GPAI model, whether it integrates that model into a system, and whether it uses a system under the deployer role. The legal consequences of each answer still depend on the applicable provisions and the facts; a role inventory is an organizing tool, not a substitute for interpreting the Act.
When an organization only deploys a system
Deployment is a distinct role from providing the GPAI model and from providing the AI system. The Commission’s Article 50 FAQ gives the AI-system-provider definition and addresses some transparency duties, but the source material available for this article does not establish the complete Article 26 deployer-duty list. Do not infer that list from the GPAI rules or from the fact that an organization uses an AI system; check the current Article 26 text for the relevant system and circumstances.
Similarly, this overview does not set out a full Article 25 test for when an actor is treated as the provider of an AI system. That question should not be answered with an improvised rule based only on integration or deployment. Consult the current consolidated provision and assess the specific arrangement before deciding whether a downstream actor has a provider role or which obligations follow.
How should an organization map its AI Act responsibilities?
Start by separating the model, the AI system that incorporates it, and the organization’s role in relation to each. Then confirm the applicable provisions against the current consolidated Act. The following sequence helps organize that review without treating role labels as a substitute for legal analysis.
- Identify the GPAI model relationship. Determine which organization provides the model and whether the model is being supplied for integration into an AI system.
- Identify the AI-system relationship. Establish who develops, places on the market or puts into service the system that incorporates the model, and who uses it as a deployer.
- Check for role overlap. If one organization provides the model and also integrates it into a system, assess both the model-provider requirements and the system-provider requirements applicable to that system.
- Apply the Article 53 baseline where relevant. Check the technical documentation, downstream information, copyright policy, public training summary and cooperation requirements.
- Assess systemic risk separately. Check the current legal provisions and Commission guidance; if the model is treated as systemic-risk GPAI, assess the additional Article 55 requirements.
- Verify downstream duties in the operative text. Consult the current Articles 25 and 26 for provider reclassification and deployer duties rather than relying on an incomplete checklist or assuming the model provider’s compliance resolves them.
- Keep evidence aligned to each duty. Record which organization owns each model-level or system-level task, what information is shared, and which current legal provision supports the allocation.
For a useful working record, keep the role questions and the obligations questions separate. First establish which organization may be acting as model provider, system provider or deployer. Then map each potentially applicable duty to its layer, recipient and relevant provision. For the model-provider layer, this means distinguishing authority-facing technical documentation, information for integrating system providers, the copyright policy, the public training summary and cooperation. For systemic-risk models, record the separate Article 55 areas as well.
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At the downstream layer, do not fill gaps in the record by assuming the GPAI provider’s paperwork is a complete system compliance file. The Commission describes model-provider cooperation as helping downstream system providers meet their own obligations, which confirms that the downstream assessment remains necessary. Where the Article 25 or Article 26 answer is material, use the operative text rather than relying on an abbreviated role chart.
What is binding law, and what is guidance or a voluntary compliance aid?
The EU AI Act is the binding regulation. The European Commission’s GPAI scope guidelines explain its approach but are not legally binding; the Commission says only the Court of Justice of the European Union can provide an authoritative interpretation. The Commission also says it will base enforcement on the guidelines, while case-specific assessment remains necessary.
The GPAI Code of Practice is a voluntary compliance aid, not a new set of AI-system obligations. The Commission presents it as an adequate way for model providers to demonstrate compliance with provider duties, and says it concerns Articles 53 and 55. Following the Code should not be described as mandatory, nor should the Code be treated as a replacement for checking which system-level provisions apply to a downstream organization.
This distinction matters when translating guidance into a compliance plan. The regulation is the binding legal text; Commission guidance explains the Commission’s approach and informs its stated enforcement basis, but does not itself supply an authoritative judicial interpretation. The voluntary Code is a way for GPAI model providers to demonstrate compliance with the relevant provider obligations. It should not be described as compulsory or as a code for every company that deploys an AI system.
The Commission’s service-desk page on Article 53 says it is based on the consolidated AI Act as at 27 July 2026. Because guidance and thresholds can change, use the current consolidated regulation and current Commission materials when assessing a live product or deployment.
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Which mistakes most often blur the responsibilities?
- Treating model provider and system provider as synonyms. The model and the AI system are separate regulatory layers, and one organization can have duties at both.
- Assuming every downstream user is a model provider. Using or deploying a GPAI-based system does not, by itself, establish that the organization provides the underlying model.
- Assuming all model providers are deployers. Providing a model does not automatically mean the organization uses a resulting AI system as a deployer.
- Calling the open-source exception comprehensive. The described exception is limited to two documentation duties, is conditional, and is unavailable for systemic-risk GPAI models.
- Treating Commission guidance as the regulation. Guidelines inform the Commission’s enforcement approach but are not legally binding, and the Court of Justice of the European Union alone provides authoritative interpretation.
- Using a compute threshold as a universal answer. The Commission describes a systemic-risk presumption above 1025 FLOP and says the threshold is under review; it should not be presented as an unchanging substitute for the applicable legal assessment.
- Importing an incomplete deployer checklist. The complete Article 26 analysis and the Article 25 provider-reclassification test require verification in the operative provisions.
- Confusing the two documentation audiences. Technical documentation for authorities and specified information for system providers intending to integrate the model are separate Article 53 duties with different recipients and purposes.
- Treating the training summary as the technical file. The public summary of training content is a distinct deliverable; the Commission describes it as a summary using the AI Office template, not publication of the entire technical documentation.
- Assuming voluntary means irrelevant, or mandatory. The Code of Practice is presented by the Commission as an adequate voluntary way to demonstrate provider compliance; neither calling it compulsory nor treating it as a new system-level duty reflects that framing.
Frequently Asked Questions
What obligations apply to general-purpose AI model providers?
The Article 53 baseline includes current technical documentation for the AI Office and national competent authorities; specified model information and documentation for AI-system providers intending to integrate the model; a policy to comply with Union copyright and related-rights law, including rights reservations; a public, sufficiently detailed training-content summary using the AI Office template; and necessary cooperation with the Commission and national competent authorities. Systemic-risk GPAI providers have additional Article 55 duties.
Who is a provider of an AI system?
The European Commission’s Article 50 FAQ gives a provider definition in the system context. This article describes the relevant activities as developing, placing on the market or putting an AI system into service, but the complete provider analysis—including Article 25 reclassification questions—should be checked against the current consolidated Act for the particular facts.
Does using a GPAI model automatically make an organization the model provider?
No. The roles concern different layers. A downstream organization may provide an AI system that integrates a model or deploy a system without thereby becoming the provider of the underlying GPAI model. The precise provider status for a system can require a separate Article 25 assessment.
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Does the qualifying free and open-source exception remove every Article 53 duty?
No. The exception described by the Commission may apply to Article 53(1)(a) and (b), the two documentation duties, when the license and public-availability conditions are met. It does not apply to GPAI models with systemic risk, and it does not remove the copyright-policy, public training-summary or cooperation requirements.
Are the 1023 and 1025 FLOP figures interchangeable?
No. The Commission describes more than 1023 FLOP together with language-generation capability in its GPAI scope explanation. It describes more than 1025 FLOP as a presumption of systemic risk and says that threshold is under review. These figures serve different explanatory purposes and are not measures of observed harm or model quality.
Does the GPAI compute threshold measure actual harm or model quality?
No. The Commission describes the compute figures as part of its scope and systemic-risk explanations; they are not empirical statistics about observed harm or a general quality rating. In particular, the Commission says the 1025 FLOP systemic-risk threshold is under review.
Does the Code of Practice create obligations for companies that only deploy an AI system?
The Commission says the Code concerns obligations in the Act for providers of GPAI models, specifically Articles 53 and 55. It is not described as a separate deployer code or as a source of new AI-system obligations.
Can Commission guidance settle a disputed interpretation of the AI Act?
No. The Commission says its guidelines are not legally binding and that only the Court of Justice of the European Union can give an authoritative interpretation. The Commission nevertheless says it will base enforcement on the guidelines.
Does the public training summary replace technical documentation supplied to authorities?
No. The Act’s baseline distinguishes the public, sufficiently detailed summary of training content from technical documentation prepared for the AI Office and national competent authorities. They have different audiences and are separate provider obligations.
What should a downstream organization verify about its deployer duties?
The complete Article 26 deployer-duty list is not set out here. Check the current consolidated Article 26 provisions for the system and circumstances instead of inferring deployer duties from GPAI model-provider requirements or from the fact that the organization uses an AI system.
The Bottom Line
GPAI model-provider duties attach to the model; system-provider and deployer duties attach to the AI system and the organization’s role in relation to it. Article 53 sets out the model-provider baseline, while systemic-risk models bring additional Article 55 duties. Downstream organizations retain their own applicable system-level responsibilities, and a single organization can hold multiple roles. Use the current consolidated Act to resolve Article 25 and Article 26 questions, and treat Commission guidance and the voluntary Code of Practice according to their stated status.
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