AI Act GPAI and downstream provider roles

This screen sorts which AI Act role may apply when an organisation develops, changes, integrates, or represents a general-purpose AI model. It is separate from a general AI Act readiness review.

GPAI model role

A provider of a GPAI model has Article 53 duties, including technical documentation, information for downstream providers, a copyright policy, and a training-content summary. A provider outside the EU generally needs an authorised representative before the model is placed on the Union market, subject to the statute's own exceptions. An entity that only integrates the model does not automatically become the provider of that model.

Downstream AI-system role

Integrating a GPAI model into a separate AI system can leave the organisation as a downstream AI-system provider. Offering that system to third parties can bring AI-system provider duties, which stay separate from GPAI model-provider status.

Modification role

Fine-tuning or another change does not automatically make a downstream actor the provider of the GPAI model. Provider-level duties for the modified model may arise when the change is sufficiently significant, including a material change of capabilities or intended purpose, or substantial further training. One signal is not a legal conclusion. The Commission guidelines on the scope of GPAI provider obligations are the reference. This screen has no compute threshold.

Authorised representative role

An EU established entity with a written mandate can act as authorised representative for a GPAI provider established outside the EU. A missing or unknown mandate is a review, not a confirmed representative role.

Systemic-risk review

Additional Article 55 duties apply to a GPAI model with systemic risk. This screen uses only a designation or status that is already known. An unknown status is not treated as systemic risk.

Transitional timing

GPAI obligations apply from 2 August 2025. Commission enforcement powers apply from 2 August 2026. A GPAI model placed on the market before 2 August 2025 has a transitional date of 2 August 2027. That transition is not a current release from the duties.

GPAI Code of Practice

The GPAI Code of Practice is voluntary. It can help a provider show how duties are met, and signing it is not required to decide a role. Not signing it is not, by itself, a failed result.

Examples

A third-party GPAI model is integrated into a service with no significant change: likely downstream AI-system provider.
The organisation develops a GPAI model and places it on the EU market under its own name: likely GPAI model provider.
Fine-tuning changes capabilities in a significant way: possible GPAI provider after significant modification.
An EU entity holds a written mandate for a non-EU GPAI provider: likely authorised representative.
A GPAI model was placed before 2 August 2025: transitional GPAI review, with 2 August 2027 as the transition date.

Limits

This does not establish a confirmed AI Act role. There is no numeric score and no compute threshold. The screen does not accept model names, organisation names, training data, prompts, or free text. Later Commission guidance or a new designation is a manual review.

AI Act GPAI and downstream provider roles