EU AI Act
Is my model a General Purpose AI Model under Article 53?
6 questions to determine whether your AI model qualifies as a GPAI under the EU AI Act and what obligations Article 53 imposes on you.
Last updated: 1 May 2025
Do GPAI model obligations need to comply with EU AI Act?
6 questions to determine whether your AI model qualifies as a GPAI under the EU AI Act and what obligations Article 53 imposes on you. If yes: GPAI with systemic risk — enhanced obligations apply. If not: Model likely below GPAI threshold — standard rules apply. Use the interacti…
- Yes path: GPAI with systemic risk — enhanced obligations apply
- No path: Model likely below GPAI threshold — standard rules apply
- Use the step-by-step decision tree below for your exact situation
EU AI Act · Question 1
Is your model capable of serving a wide range of distinct tasks across many domains, rather than being trained for a single specific purpose?
GPAIs can write code, summarise documents, answer questions, generate images — across domains. A fraud-detection model for banking only is not a GPAI. GPT-4, Claude, Llama, Mistral, Gemini are GPAIs.
For informational purposes only. Consult qualified legal counsel before making compliance decisions.
Decision tree questions
Is your model capable of serving a wide range of distinct tasks across many domains, rather than being trained for a single specific purpose?
GPAIs can write code, summarise documents, answer questions, generate images — across domains. A fraud-detection model for banking only is not a GPAI. GPT-4, Claude, Llama, Mistral, Gemini are GPAIs.
- Yes: Continue to: Was your model trained using significant computational resources — more than 10^23 FLOPs?
- No: Not a GPAI — narrow task-specific model
Was your model trained using significant computational resources — more than 10^23 FLOPs?
10^23 FLOPs is the lower threshold triggering GPAI classification. Most frontier models exceed this. For reference, training GPT-3 used approximately 3.14 × 10^23 FLOPs.
- Yes: Continue to: Is your model released as open source with publicly available weights?
- No: Model likely below GPAI threshold — standard rules apply
Is your model released as open source with publicly available weights?
Open-source GPAI models with published weights have a lighter compliance path — they are exempt from some documentation requirements under Art. 53(2), unless they present systemic risk.
- Yes: Continue to: Was your model trained with more than 10^25 FLOPs — indicating potential systemic risk?
- No: Continue to: Do you make your GPAI available to other businesses or developers who build downstream applications on top of it?
Was your model trained with more than 10^25 FLOPs — indicating potential systemic risk?
10^25 FLOPs is the systemic-risk threshold under Art. 51. Models above this threshold face enhanced obligations regardless of open-source status.
- Yes: GPAI with systemic risk — enhanced obligations apply
- No: Open-source GPAI — reduced obligations, baseline compliance needed
Do you make your GPAI available to other businesses or developers who build downstream applications on top of it?
If you provide an API, SDK, or model weights to third-party providers who embed your model in their products, you have additional information obligations toward those downstream providers.
- Yes: GPAI provider with downstream users — full Art. 53 obligations
- No: GPAI for internal use — Art. 53 still applies