Colorado ADMT rules: hearing and last day for written comments · Oct 26, 2026 · See what changes
General Purpose AI Model: the EU AI Act's formal term for a foundation model trained on large amounts of data and capable of performing a wide variety of tasks. The EU AI Act imposes specific obligations on GPAI model providers, including documentation requirements and cooperation with downstream providers that build on their models. If you build a product on top of an API like OpenAI or Anthropic, you are not a GPAI model provider. You are the provider of your own AI system (the Act calls this a 'downstream provider'), and the deployer of it if you use it yourself.
Why this matters for your team
If you build on top of an API like OpenAI or Anthropic, the GPAI model obligations stay with the model provider. Your obligations depend on what your AI system does: a chatbot mainly needs transparency, while using the model for something listed in Annex III, such as screening job applicants, makes you the provider of a high-risk AI system.
OpenAI's GPT-4o is a GPAI model under the EU AI Act. A company that builds a customer service chatbot on the GPT-4o API and offers it under its own name is the provider of that chatbot, not a GPAI model provider.