Governance Briefing — August 21, 2025
General-purpose AI providers have roughly three months until the EU AI Act’s transparency and systemic-risk duties become enforceable, demanding documentation, copyright notices, and evaluation pipelines now.
Executive briefing: The EU Artificial Intelligence Act enters into force in 2024, with obligations for general-purpose AI (GPAI) models applying 12 months later. By autumn 2025, GPAI providers must publish detailed summaries of training content, implement technical documentation, and establish risk management, cybersecurity, and incident reporting aligned with Articles 52a and 52b.
Key governance checkpoints
- Training data transparency. Compile and publish high-level descriptions of datasets used, including copyrighted works, data sources, and filtering processes.
- Technical documentation. Produce model cards covering capabilities, limitations, benchmark results, energy use, and foreseeable misuse scenarios suitable for market surveillance authorities.
- Risk management. Establish monitoring programs for systemic risks, including red teaming, adversarial testing, and safeguards against generating illegal content.
Operational priorities
- Downstream support. Prepare documentation and API features enabling deployers to meet Article 52 obligations, such as usage policies, opt-out tooling, and content provenance signals.
- Incident response. Define reporting channels to notify the European AI Office of serious incidents or corrective measures within 15 days.
- Copyright notices. Implement user-facing notices that disclose the use of copyrighted training data and provide mechanisms for rights holder opt-outs where applicable.
Enablement moves
- Integrate watermarking or content authenticity metadata to support provenance obligations and downstream moderation.
- Stand up governance councils that review systemic risk metrics, deployment guardrails, and audit logs on a monthly cadence.
Sources
Zeph Tech deploys AI governance frameworks, documentation pipelines, and copyright transparency tooling to meet the EU AI Act’s GPAI mandates.