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AI Act general-purpose AI: the obligations of GPAI providers under Articles 51 to 56, in force across the EU since 2 August 2025.

Chapter V of Regulation (EU) 2024/1689 introduces a separate regime for general-purpose AI (GPAI) models. Article 53 sets four documentation and transparency obligations for every GPAI provider. Article 51 classifies models as having systemic risk when training computation exceeds 10²⁵ floating-point operations, triggering the additional obligations of Article 55 — model evaluations, systemic-risk assessment, serious-incident reporting, and cybersecurity. Free and open-source models benefit from a narrow carve-out under Art. 53(2). Chapter V applies from 2 August 2025; pre-existing GPAI models on the market before that date must comply by 2 August 2027 under Art. 111(3).

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Regulation (EU) 2024/1689 · Article 11 + Annex IV · 12 documents · 100% browser-side — your data never leaves your machine

The numbers

Chapter V
Articles 51 to 56 — GPAI models. Separate regime from Annex III high-risk AI systems.
10²⁵ FLOPs
Art. 51(2) presumption: a GPAI model is presumed to have high impact capabilities — and thus systemic risk — when training compute exceeds 10²⁵ FLOPs.
2 Aug 2025
Application date under Art. 113(b). Pre-existing GPAI models on the market before this date have until 2 Aug 2027 to comply (Art. 111(3)).

The four Article 53 obligations, plus the Article 55 systemic-risk overlay

Article 53 sets the baseline. Every GPAI provider in scope must meet four obligations. Where the model meets Article 51 thresholds, Article 55 adds four more.

a
Art. 53(1)(a) — Technical documentation under Annex XI
Draw up and keep up-to-date the technical documentation of the model, including the training and testing process and the results of its evaluation, containing at a minimum the information set out in Annex XI. Provided to the AI Office and national competent authorities upon request.
b
Art. 53(1)(b) — Information for downstream AI system providers (Annex XII)
Draw up, keep up-to-date and make available information to providers of AI systems intending to integrate the GPAI model. Must enable downstream providers to understand capabilities and limitations and to comply with the Regulation. Minimum elements in Annex XII.
c
Art. 53(1)(c) — Copyright policy
Put in place a policy to comply with Union law on copyright and related rights, in particular to identify and comply — including through state-of-the-art technologies — with reservations of rights expressed under Article 4(3) of Directive (EU) 2019/790 (DSM Directive).
d
Art. 53(1)(d) — Public summary of training data
Draw up and make publicly available a sufficiently detailed summary about the content used for training the GPAI model, according to a template provided by the AI Office. Cannot be waived even for free/open-source models — Art. 53(2) carve-out covers (a) and (b) only.
Art. 51 — Classification with systemic risk
A GPAI model is classified as systemic-risk if (a) it has high impact capabilities evaluated on appropriate technical benchmarks, OR (b) the Commission designates it ex officio or following a qualified alert from the scientific panel. Art. 51(2): a model is presumed to have high impact capabilities when cumulative training compute is greater than 10²⁵ FLOPs. The provider must notify the Commission within two weeks of meeting (or expecting to meet) the threshold (Art. 52(1)).
Art. 55 — Additional obligations for systemic-risk GPAI
(a) Perform model evaluations in accordance with standardised protocols and tools, including conducting and documenting adversarial testing. (b) Assess and mitigate possible systemic risks at Union level, including their sources. (c) Track, document and report serious incidents to the AI Office and, where appropriate, to national competent authorities — without undue delay. (d) Ensure an adequate level of cybersecurity protection for the model and its physical infrastructure.
Art. 54 — Authorised representative for third-country GPAI providers
Providers established outside the EU must, by written mandate before placing the GPAI model on the Union market, appoint an authorised representative established in the Union. The representative keeps a copy of the Annex XI technical documentation for 10 years and cooperates with the AI Office.
Art. 56 — Codes of practice
Until harmonised standards are published, GPAI providers may rely on codes of practice to demonstrate compliance with Art. 53 and Art. 55. Compliance with European harmonised standards grants presumption of conformity. Providers not adhering to a code or standard must demonstrate alternative adequate means of compliance, assessed by the Commission.

Three common mistakes

COMMON MISTAKE

"Our model is open-source, so no AI Act obligations apply"

Art. 53(2) exempts free and open-source GPAI providers from points (a) and (b) — the technical documentation and downstream-provider documentation. Points (c) (copyright policy) and (d) (training-data summary) still apply. And the exemption does NOT apply to GPAI models with systemic risks — those carry the full Art. 53 + Art. 55 load regardless of licensing.

COMMON MISTAKE

"Using a GPAI model in our product makes us a GPAI provider"

No. Integrating someone else's GPAI model into your AI system makes you a provider of the AI system (Art. 3(3)), not a provider of the GPAI model. Your obligations are those of the AI system provider (Art. 16 if high-risk) plus the downstream-user duties enabled by the GPAI provider's Art. 53(1)(b) documentation. The GPAI obligations themselves remain with the model developer.

COMMON MISTAKE

"The 10²⁵ FLOPs threshold is the only path to systemic risk"

Art. 51(1)(a) is the presumption path (10²⁵ FLOPs). But Art. 51(1)(b) and Art. 52(4) let the Commission designate a model as systemic-risk ex officio or following a qualified alert from the scientific panel, based on the criteria in Annex XIII — without the FLOPs threshold. A capable smaller model can still be classified as systemic-risk.

Does the AI Act apply to your system?

Answer these four questions to determine your obligations.

Does your system use machine learning, logic-based, or statistical approaches?
Art. 3(1) — definition of "AI system"
Is the system placed on the EU market or does its output affect persons in the EU?
Art. 2(1) — territorial scope (extraterritorial via 2(1)(c))
Is your system used in any Annex III domain? (employment, credit, education, law enforcement, migration, justice, critical infrastructure, biometrics)
Art. 6(2) + Annex III — high-risk classification
Are you the provider (developer) or the deployer (user) of the system?
Art. 3(3) provider · Art. 3(4) deployer — different obligations

Take the full AI Act risk classification test →

What the ZIP contains

12 PDF documents generated from your inputs. Each cites the article of Regulation (EU) 2024/1689 it fulfils.

1

Risk Classification Report

Identifies whether your system is prohibited (Art. 5), high-risk (Art. 6 + Annex III) or subject to transparency obligations (Art. 50).

2

Technical Documentation

The 9 blocks of Annex IV in full: system description, training data, validation, performance metrics, risk management, human oversight. Art. 11 + Annex IV.

3

EU Declaration of Conformity

Signable document conforming to Art. 47 and Annex V.

4

Compliance Calendar

Key application dates: 2 Feb 2025, 2 Aug 2025, 2 Aug 2026, 2 Aug 2027. Art. 113.

5

Conformity Sheet

Executive summary of compliance status for authorities or commercial buyers. Art. 43 procedure.

6

Quality Management System (QMS)

QMS structure covering the 13 aspects required by Art. 17.

7

Deployer Instructions

Document for the entity deploying your system, conforming to Art. 13.

8

Evidence Checklist

Verifiable evidence list, cross-referenced to every Annex IV block.

9

Incident Report Template

Notification protocol conforming to Art. 73 (15 days general / 10 days death / 2 days widespread).

10

AI Literacy Programme

Training plan conforming to Art. 4, in force since 2 February 2025.

11

Post-Market Monitoring Plan

Plan structure required by Art. 72 and integrated into the technical documentation under Annex IV(9).

12

Fundamental Rights Impact Assessment (FRIA)

Template under Art. 27 for public bodies, private entities providing public services, and Annex III 5(b)(c) deployers.

See before you buy — Download a sample dossier (PDF, fictional company) — Real structure, real articles, real format. Fictional data.

Generated from your inputs, in your browser. No data leaves your machine.

What you pay

🧾 AI ACT COMPLIANCE CONSULTANCY
€5,000–€15,000
3–6 months. They explain the obligations to you.
✓ AICHECK
€249
12 documents. 45 minutes. Solves the documentation.

Technical documentation and conformity assessment: two layers

● LAYER 1

Technical documentation — Annex IV

12 documents. 45 minutes. €249. The documentation your system needs before being placed on the market.

∅ LAYER 2

Conformity assessment by notified body

If your system falls under Art. 43(1) (Annex III point 1 biometrics with notified-body route, or Annex I products), you will need third-party conformity assessment. That is a separate process. AICheck does not replace it.

We do not sell audits. We do not sell consultancy. We sell the tool that structures your documentation under Annex IV.

Penalty regime

Article 99 of Regulation (EU) 2024/1689. Chapter XII (Penalties) applies from 2 August 2025.

🇪🇺
Non-compliance with prohibited practices (Art. 5)
€35M / 7%

Art. 99(3). Up to €35 million or 7% of total worldwide annual turnover, whichever is higher. For SMEs and start-ups: whichever is lower (Art. 99(6)).

🇪🇺
Non-compliance with operator obligations (high-risk, transparency, deployer)
€15M / 3%

Art. 99(4). Includes failure to draw up technical documentation under Art. 11 + Annex IV. Covers obligations of providers (Art. 16), deployers (Art. 26), authorised representatives (Art. 22), importers (Art. 23), distributors (Art. 24), notified bodies (Art. 31, 33, 34) and transparency under Art. 50.

🇪🇺
Supply of incorrect, incomplete or misleading information
€7.5M / 1%

Art. 99(5). Applies when information provided to notified bodies or national competent authorities is wrong or misleading.

Documenting 5 or more AI systems?

If you operate multiple AI systems and need to document them all under Annex IV, contact us for volume pricing at hello@solidwaretools.com.

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What AICheck guarantees, and what it does not

AICheck produces a document structured under Article 11 and Annex IV of Regulation (EU) 2024/1689 from the information you provide. The accuracy, truthfulness and completeness of that information is your responsibility as provider of the AI system.

We guarantee that the document structure follows Article 11 and Annex IV of Regulation (EU) 2024/1689 and that the legal references cited are correct as of the last verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a given case, nor by a commercial buyer in a procurement process.

AICheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

What is a GPAI model under the AI Act?
Art. 3(63) defines a general-purpose AI model as an AI model, including where trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks, regardless of the way the model is placed on the market, and that can be integrated into a variety of downstream systems or applications. Excludes models used for research, development or prototyping before placement on the market.
What is a GPAI model with systemic risk?
Art. 51 — a GPAI model is classified as systemic-risk if it has high impact capabilities (technical benchmarks) or is so designated by the Commission. Art. 51(2) sets a presumption: training compute greater than 10²⁵ FLOPs. The provider must notify the Commission within two weeks under Art. 52(1). Systemic-risk classification triggers the four additional Art. 55 obligations: model evaluations, systemic-risk assessment, incident reporting to the AI Office, cybersecurity.
When do GPAI obligations apply?
Chapter V applies from 2 August 2025 under Art. 113(b). For GPAI models already on the market before 2 August 2025, Art. 111(3) gives a transitional period until 2 August 2027. Penalty regime: Article 101 (specific GPAI penalties) is excluded from the 2 August 2025 application of Chapter XII — penalties for GPAI providers follow a slightly different timing under Art. 113(b).
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The PDF you download is yours to keep.
Can I request a refund?
Pursuant to Article 16(m) of Directive (EU) 2011/83 on consumer rights, by activating the licence you give express consent to the immediate generation of digital content, waiving the 14-day withdrawal right. Refunds are only accepted in the case of a reproducible technical failure.
What if the regulation changes?
If the regulation changes while your licence is active, you can regenerate the document with the updated version of the generator at no additional cost.
⚠️ Important notice: AICheck is a documentary self-assessment tool, not legal advice nor a third-party audit. The document under Article 11 and Annex IV of Regulation (EU) 2024/1689 is generated from the data you input. The accuracy of that data is your responsibility. AICheck does not replace a qualified professional assessment.

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Twelve documents. Annex IV fully structured. Regulation (EU) 2024/1689. Your data does not leave your machine. The ZIP you download is yours to keep.

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✓ Last regulatory verification: 11 May 2026 · No substantive changes detected · View history