What Are the EU GPAI Guidelines Under the AI Act?

The European Commission’s AI Office opened a public consultation on upcoming Commission Guidelines for General-Purpose AI (GPAI) models under the EU AI Act. These guidelines clarify the specific obligations for providers of general-purpose AI, with adoption anticipated in May or June 2025.

Why the Commission Is Issuing GPAI Guidance

The AI Act, adopted in 2024, introduces binding rules for general-purpose AI models — including documentation standards, copyright compliance, systemic risk management, and notification duties.

According to Article 3(63) of the AI Act:

‘General-purpose AI model’ means an AI model trained with large datasets using self-supervision, capable of competently performing a wide range of distinct tasks, and deployable across various systems or applications. Models used solely for research, development, or prototyping are excluded.

The GPAI guidelines aim to:

• Explain when a model should be considered a general-purpose AI model
• Clarify the difference between models and model versions
• Clarify who counts as a provider (including downstream modifiers)
• Explain when a model is "placed on the market"
• Detail how to estimate training compute thresholds linked to systemic risk

Main Issues Open for Feedback in the Consultation

Stakeholders are invited to comment on several topics:

• Definition and Scope of GPAI Models: Determining if a model demonstrates sufficient "generality and capabilities," potentially using training compute (FLOP) metrics.
• Thresholds for Providers and Downstream Modifiers: Defining when a downstream actor becomes a "provider" under the AI Act.
• Treatment of Open-Source AI Models: Establishing exemptions for models released under free and open-source licenses.
• Estimating Training Compute: Guidelines for measuring compute resources used in model development and fine-tuning.
• Systemic Risk Identification: Setting thresholds and compliance obligations for models posing systemic risks.

Respondents can also comment on proposed scenarios, formulas, and examples included in the working document.

What Comes Next? Other Guidance Under the AI Act

The GPAI Guidelines are part of a broader package to support EU AI Act implementation. Documents expected in 2025 include:

• General-Purpose AI Code of Practice: Voluntary commitments for GPAI providers (mid-2025)
• Template for Summary of the Content Used for Training: To assist with AI Act Article 53(1)(d) compliance

Already Published AI Act Guidance (2025)

The Commission has released the following resources:

• Guidelines on AI System Definition
• Guidelines on Prohibited AI Practices
• Repository of AI Literacy Practices
• AI Act FAQ

These documents are available on Streamlex.eu, along with the full text of the EU AI Act..

Who Should Participate in the GPAI Consultation?

Participation in the consultation is relevant for:

• Developers and providers of foundation models
• Companies modifying or fine-tuning AI models
• Compliance professionals evaluating GPAI exposure
• Organizations involved in AI governance and risk management

How to Respond Before the 22 May 2025 Deadline

The public consultation is open until 22 May 2025. Stakeholders can respond via the designated consultation form.

Streamlex will continue monitoring developments and will update the resources hub once the final GPAI guidelines are published. Want updates on final AI Act guidelines? Subscribe to our Streamlex newsletter.