Your Practical Guide to the EU AI Act and GPAI Guidelines

As of August 2nd, 2025, the EU AI Act’s provisions for General Purpose AI (GPAI) models are officially in force. With the release of the GPAI Guidelines, the European Commission has delivered long-awaited clarity on how these new rules apply in practice. The guidelines help developers, deployers, and other stakeholders across the AI value chain understand their responsibilities and innovate confidently within the EU regulatory framework.

On this page, you'll find:

  • A concise summary of the most important rules, definitions, and obligations introduced by the AI Act,
  • Our practical tips and implementation guidelines to help you embed these requirements into your internal AI governance processes effectively.

Whether you're building, integrating, or deploying AI systems, our goal is to help you move from regulation to action - faster and with greater confidence.

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EU AI Act GPAI Guidelines

Key Takeaways and Summary of GPAI Guidelines for Downstream Providers

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How to implement the AI Act Rules into your business
5‑Step Guide for Downstream Providers of GPAI Models​

If your company is integrating or modifying General-Purpose AI (GPAI) models trained with more than 10²³ FLOP of compute into your AI products or services, the following steps can help you navigate your obligations under the EU AI Act:​

1️⃣ Create a Use Case Inventory​

Maintain an up-to-date inventory of all AI systems containing GPAI models. Document key details such as licensing information, estimated training compute (FLOP), to confirm whether each model exceeds the 10²³ FLOP (GPAI) or 10²⁵ FLOP (systemic risk) thresholds. FLOP estimates for widely used models are available in public registries; for others, ask your technical team to calculate them in line with the GPAI guidelines.​

2️⃣ Assess gaps and setup policies in your AI Act Governance framework​

Based on the AI Act, Code of Practice and GPAI guidelines, setup policies to be applied to each GPAI model, in order to determine your obligations. As most downstream providers do not train models from scratch, focus efforts on the obligations related to integrating or modifying a GPAI model, based on the thresholds defined in the GPAI guidelines.​

3️⃣ Update Use Case Prioritization​

Integrating or modifying GPAI models may trigger different levels of compliance obligations. Update your use case prioritization and approval process to reflect this new complexity, taking into account the model’s origin, compute threshold, and extent of modification.​

4️⃣ Execute and Monitor Compliance Policies​

Apply your policies consistently each time your AI engineers want to develop, integrate, or modify a GPAI model. Ensure evidence of compliance is generated and retained. Based on your organization’s risk appetite, consider setting up multiple lines of defense: Development teams, ethical AI or responsible AI officers, external audits or third-party validations.​

5️⃣ Upskill your workforce​

Depending on your obligations, define and execute proper AI literacy training for the AI user, AI system developers and deployers.​

The GPAI guidelines provide clarity, helping organizations better understand whether the obligations apply to them. To ensure compliance, these obligations must be thoroughly understood and embedded into your AI governance framework, by jointly examining the AI Act, the GPAI guidelines, and the Code of Practice. Apply them consistently every time your AI engineers want to develop, integrate, or modify a GPAI model.

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Alexander Machado, Head of Trustworthy AI at appliedAI

Talk with Germany's top AI Act operationalization experts

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Alexander Machado
Alexander Machado (Head of Trustworthy AI (COE) is there for you if you have questions
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