Policy Briefing — EU AI Act general-purpose model duties enter force on 1 August 2025
Twelve months after the EU AI Act enters into force, providers of general-purpose AI models must publish technical documentation, systemic-risk mitigation plans, and EU database disclosures or face market surveillance investigations.
Executive briefing: Regulation (EU) 2024/1689 (the EU AI Act) entered into force on 1 August 2024. Article 113(2)(b) sets a 12-month application window for general-purpose AI (GPAI) obligations, making 1 August 2025 the first enforcement date. Providers must deliver detailed technical documentation, summaries of training data, systemic risk mitigation measures for high-impact models, and notify the EU database for GPAI models before placing systems on the market.
Core obligations
- Documentation packages. Articles 53(1)–(3) require GPAI providers to supply descriptions of model capabilities, training and evaluation data, performance limitations, and alignment techniques to deployers and competent authorities.
- Systemic-risk controls. Article 53(4) and Article 55 impose additional duties on GPAI models with systemic risk, including risk management policies, incident reporting within 15 days, and adversarial testing programmes.
- Transparency disclosures. Article 54 obliges providers to publish detailed summaries of copyrighted training content and to register models in the EU database managed by the AI Office.
Program actions
- Model inventory. Identify foundation models offered in the EU, classify whether they meet the systemic-risk thresholds under Annex XI, and map existing documentation gaps.
- Evidence packs. Build reusable documentation kits covering training data governance, evaluation results, safeguards, and intended use restrictions to satisfy Article 53 templates.
- Incident playbooks. Align global AI incident reporting, bias mitigation, and security response plans so EU notifications flow within the 15-day statutory window.
Enablement moves
- Coordinate with deployer customers on downstream transparency duties, including user disclosures and monitoring expectations.
- Engage legal and public policy teams to monitor delegated acts defining systemic-risk thresholds and to plan conformity assessment pathways.