EU AI Act obligations for general-purpose models take effect
From 2 August 2025 the EU AI Act required providers of general-purpose AI models newly placed on the market to keep technical documentation, publish a summary of their training data, comply with EU copyright law, and share information with regulators and downstream developers.
Why it mattered It was the first provision of the Act to bind the makers of foundation models such as GPT, Claude, and Gemini, four years after the law was first proposed.
The European Commission proposed the Artificial Intelligence Act in April 2021, more than a year before ChatGPT put general-purpose systems in front of the public. The Act’s design regulated AI by the use a system was put to, a scheme with no obvious place for a model that can be put to almost any use. The chapter that took effect on 2 August 2025 is the answer the Union settled on.
It applies to providers of general-purpose AI models placed on the European market from that date. Each must keep technical documentation on the model, publish a summary of the content used to train it, maintain a policy for complying with EU copyright law, and share information with regulators and with the downstream developers who build on the model. The European Commission published guidelines on the scope of those duties in July 2025, together with a voluntary Code of Practice that providers could sign to show how they meant to comply.
The calendar is as consequential as the text. Models already on the market before 2 August 2025 have until 2 August 2027 to comply, so the immediate reach was limited to new releases. The Commission also cannot bring an enforcement action under these provisions until 2 August 2026, which gave providers a year in which the obligations applied without a penalty attached to them.
The training-data summary is the requirement with the widest reach. No American law obliged a laboratory to say publicly what its model had read, and the fair-use rulings handed down in California six weeks earlier had turned partly on facts about data sourcing that only litigation had brought to light. From August 2025 a version of that disclosure became a condition of selling a new model into the European market, ahead of the Act’s stricter rules for high-risk systems in 2026 and 2027.