General-purpose AI models: The European Commission's guidelines on the scope of obligations

Despite industry pressure and its previous signals, the European Commission confirmed the EU Artificial Intelligence Act will take effect for general-purpose AI models beginning 2 Aug.

A lack of published guidelines defining general-purpose AI models led to speculation that AI Act enforcement would be delayed. Meeting its obligation under Article 96(1), the Commission published the General-Purpose AI Code of Practice on 10 July to clarify key concepts and enable the enforcement of obligations on general-purpose AI model providers by the originally established deadline.

What are general-purpose AI models?

To understand general-purpose AI models, it is important to recognize the main differences between "AI systems" and "general-purpose AI models" under the AI Act.

AI systems are applications — often referred to as agents — that may, but don't have to, build on a general-purpose AI model. General-purpose AI models serve as the infrastructure layer that requires additional components, such as a user interface, to function as AI systems. AI models are typically integrated into and become part of AI systems.

Article 3(63) defines general-purpose AI models as being trained on large amounts of data, "capable of competently performing a wide range of distinct tasks" and able to be "integrated into a variety of downstream systems or applications."