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The EU rules for general-purpose AI models are in force: what deployers should ask their providers

Since August 2, 2025 the companies behind foundation models owe documentation, copyright policies and training-data summaries. Deployers can use those duties as a due-diligence checklist.

By IAIM Editorial · · Last reviewed · Updated · 4 min read

Update, : The high-risk dates mentioned here moved. Regulation (EU) 2026/1744, in force since July 27, 2026, defers the stand-alone high-risk obligations to December 2, 2027 and those for AI in regulated products to August 2, 2028; the general-purpose model duties described here are unchanged. See the EU AI Act after the Digital Omnibus.

In short: since August 2, 2025, companies that provide general-purpose AI models in the EU owe technical documentation to the businesses that build on them, a copyright policy and a public summary of their training content, with extra duties for the most capable models. For a deployer, those duties are a ready-made due-diligence checklist: ask for the documents the law now requires.1,2

The EU Artificial Intelligence Act, Regulation (EU) 2024/1689, entered into force on August 1, 2024 and applies in stages.1 The prohibited practices have applied since February 2, 2025. The next stage arrived on August 2, 2025, when the obligations for providers of general-purpose AI models began to apply: the large language and multimodal models that most business AI products are built on.1,2

Sources

  1. Regulation (EU) 2024/1689 (Artificial Intelligence Act), Official Journal of the European Union; Articles 25, 53, 54, 55, 101, 111(3) and 113 (opens in a new tab) eur-lex.europa.eu
  2. European Commission, "General-purpose AI obligations under the AI Act" (updated August 1, 2025) (opens in a new tab) digital-strategy.ec.europa.eu
  3. WilmerHale, "European Commission Issues Guidelines for Providers of General-Purpose AI Models" (July 24, 2025) (opens in a new tab) wilmerhale.com
  4. European Commission, "The General-Purpose AI Code of Practice" (July 10, 2025) and list of signatories (opens in a new tab) digital-strategy.ec.europa.eu
  5. European Commission, AI Act regulatory framework and implementation timeline (opens in a new tab) digital-strategy.ec.europa.eu

IAIM articles are educational and are not legal advice.

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