AI Act Monitor
Enforcement of GPAI obligations has started
The obligations for general-purpose AI providers are no longer only a preparation issue. The Commission can now investigate compliance and impose measures.
Source facts
What officially changed?
Since 2 August 2026, the Commission can enforce the obligations for providers of general-purpose AI models. The substantive obligations have applied to new models since 2 August 2025.
Legal effect
The AI Office can request documentation, conduct model evaluations and require risk mitigation measures. Models placed on the market before 2 August 2025 have a transition until 2 August 2027.
What the status means
The obligation applies. Any limited transition situations are stated in the source facts.
Analysis by Responsible AI Platform
Why is this material?
The obligations for general-purpose AI providers are no longer only a preparation issue. The Commission can now investigate compliance and impose measures.
What does this mean in practice?
Organisations offering a model or becoming a provider through substantial fine-tuning have a different position from organisations that only use a general-purpose AI service. That role determines the documentation and risk obligations.
What may need to be reassessed?
- Record whether the organisation is a general-purpose AI provider, a downstream provider or only a deployer.
- Check technical documentation, copyright policy and information for downstream parties.
- For models with systemic risk, also assess evaluations, incident processes and safety measures.
- Request concrete supplier evidence and do not treat signature of the voluntary code as a complete safe harbour.
For whom and which provisions?
Perspectives
Providing AI models, Providing AI, Using AI, Advising, Public authority
Topics
GPAI, Supervision and enforcement, Transparency
Legal evidence
Official sources
Last checked by Responsible AI Platform: 8 August 2026.
Guidelines on the scope of obligations for providers of general-purpose AI models under the AI Act
European Commission · 18 Jul 2025 · Published
The General-Purpose AI Code of Practice
European Commission / AI Office · 10 Jul 2025 · Published
Questions and answers on the Code of Practice for General-Purpose AI
European Commission, DG CONNECT · 20 Jul 2026 · Published
Related changes
Only when something changes
Follow the topics in this change
Receive only material changes that match this selection. No more than once a week.
This analysis provides general information and is not legal advice for a specific situation.