EU AI Act Guidelines for General Purpose AI Models

Summary

The European Commission's latest guidelines provide the definitive roadmap for understanding and complying with the EU AI Act's requirements for general-purpose AI models (GPAIs). Published in 2025, these official guidelines cut through the complexity by offering clear definitions of AI systems, listing explicitly prohibited practices, and establishing concrete compliance pathways for GPAI providers. For organizations developing or deploying foundation models, large language models, or other general-purpose AI systems in the EU market, these guidelines are essential reading that transforms abstract regulatory text into actionable implementation steps.

The Compliance Clock is Ticking

The EU AI Act isn't just future-proofing legislation—it's happening now, with staggered implementation dates that affect different AI systems at different times. These guidelines clarify the critical timeline:

• February 2025: Prohibition of certain AI practices takes effect
• August 2025: Requirements for high-risk AI systems begin
• August 2026: Full implementation for all AI systems

For GPAI models, the guidelines specify when compute thresholds trigger obligations (10²² FLOPs for basic requirements, 10²⁵ FLOPs for systemic risk models) and what documentation must be ready by each milestone. Missing these deadlines isn't just a compliance issue—it could mean losing access to the EU market entirely.

What Sets These Guidelines Apart

Unlike the dense legal text of the AI Act itself, these guidelines provide:

Concrete Examples: Real scenarios of what constitutes a prohibited AI practice versus acceptable use Technical Thresholds: Precise compute measurements and evaluation criteria for determining GPAI obligations Documentation Templates: Specific formats for technical documentation, risk assessments, and compliance reports Sectoral Applications: How general requirements apply across different industries and use cases

The guidelines also address the intersection between the AI Act and other EU regulations like GDPR, providing clarity on overlapping requirements rather than creating additional compliance burdens.

Your Action Plan After Reading

1. Assess Your Models: Use the provided compute threshold calculations to determine which of your AI systems qualify as GPAIs under the Act
2. Map Prohibited Practices: Review the expanded list of prohibited AI practices against your current and planned applications
3. Establish Documentation Systems: Implement the specified record-keeping requirements before they become mandatory
4. Engage with Notified Bodies: Begin relationships with EU conformity assessment bodies if you're developing high-risk AI systems
5. Monitor Updates: The Commission promises regular updates to these guidelines as implementation proceeds

Who This Resource Is For

GPAI Model Developers: Companies building foundation models, large language models, or multi-modal AI systems that could be deployed across multiple applications

Enterprise AI Teams: Organizations integrating third-party GPAI models into their products or services, particularly those serving EU customers

Legal and Compliance Teams: In-house counsel and compliance officers responsible for ensuring AI Act conformity across their organization's AI portfolio

AI Consultants and Advisors: External experts helping clients navigate EU AI regulation requirements and implementation strategies

Standards Bodies and Industry Groups: Organizations developing technical standards and best practices that align with EU AI Act requirements

Common Misunderstandings Clarified

"General Purpose" Doesn't Mean "General Use": The guidelines clarify that GPAI classification depends on technical capabilities, not intended use cases. A model designed for one specific purpose might still qualify as GPAI if it has broad technical capabilities.

Open Source Isn't Automatically Exempt: While the guidelines provide some accommodations for open-source development, they don't create blanket exemptions. Open-source GPAI models above certain thresholds still trigger compliance obligations.

B2B Sales Don't Escape Oversight: Selling GPAI models only to other businesses doesn't eliminate EU AI Act obligations. The guidelines make clear that B2B GPAI providers have specific responsibilities regardless of their customer base.