General-purpose AI models under the AI Act: who is a provider and what Article 53 requires

Last updated 27 Oct 2026 · India

Short answer. Chapter V of the AI Act (Regulation (EU) 2024/1689) applies from 2 August 2025 to providers of general-purpose AI models: those who develop such a model, or have it developed, and place it on the EU market under their own name. Article 53 requires them to keep technical documentation (Annex XI), give information to downstream providers who build on the model (Annex XII), have a policy to comply with EU copyright law, and publish a sufficiently detailed summary of the training content using the AI Office template. Models placed on the market before 2 August 2025 have until 2 August 2027. Models with systemic risk (presumed above 10²⁵ FLOPs of training compute, Article 51) carry extra Article 55 duties. A business that only uses a GPAI model through an app or API is normally a deployer, not a GPAI provider.

Quick test for an SME

Did you train or fine-tune a model and release it to others under your name? If not, Article 53 is probably not yours.
Do you build a product on someone else's model? Ask that provider for its Annex XII information.
Is your product high-risk or does it interact with people? Check the deployer and transparency duties instead (Articles 26 and 50).

Common mistakes

Thinking every ChatGPT user is a GPAI provider.
Assuming open-source means exempt from everything. The copyright policy and training summary still apply.
Ignoring the 2 August 2027 date for models already on the market.

Not legal advice. This is a free explainer of the AI Act text; dates and guidance can change, so check the official Commission pages or a qualified adviser.

Frequently asked questions

When do GPAI provider obligations apply?

From 2 August 2025; models already on the market before then have until 2 August 2027.

What does Article 53 require?

Technical documentation, information for downstream providers, a copyright compliance policy and a public summary of training content.

Is a company using ChatGPT a GPAI provider?

Normally no. It is a deployer of an AI system; the model provider carries the Article 53 duties.

Official sources

Not tax or legal advice. This is a free explainer of public rules; deadlines and rules can change by notification, so confirm on the official portal or with your CA before you file. Last checked 27 Oct 2026.

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