Early application of the AI Act: what are the new rules?

IRIS 2025-8:1/7

Justine Radel-Cormann

European Audiovisual Observatory

Though the AI Act sets its date of application for 2 August 2026 (Art. 113), some provisions have already been applicable since 2 August 2025. As explained in Recital 179, this earlier application targets providers of general-purpose AI models (GPAI), to reflect the rapid pace of technological advancements and adoption of such models. 

Under Art. 3(63), a GPAI model is an AI system trained with a large amount of data using self-supervision at scale, which displays significant generality and is capable of competently performing a wide range of distinct tasks.

Consequently, Chapter V of the AI Act establishing obligations for GPAI providers is now applicable, including Art. 53 of the Act. GPAI providers must implement policies to comply with Union law on copyright and related rights, in particular with regard to identifying and complying with reservations of rights pursuant to Article 4(3) of Directive (EU) 2019/790, including through state-of-the-art technologies. In addition, they must draw up and make publicly available a sufficiently detailed summary of the content used for training GPAI models, according to a template provided by the AI Office.

To detail these GPAI obligations, the European Commission published two guidance documents over the summer: the GPAI Code and the Template for GPAI model providers to summarise their training content.  

The GPAI Code offers guidance on compliance in three areas (transparency, copyright, safety/security). GPAI providers who voluntarily sign the Code will be able to demonstrate compliance with the relevant AI Act obligations by adhering to it. In doing so, signatories to the Code will benefit from a reduced administrative burden and increased legal certainty compared to providers that prove compliance in other ways. The Code has now been signed by more than 25 companies (eg. Amazon, Google, MistralAI, OpenAI).

The template is a standardised form to assist GPAI providers to summarise the content used to train their model.  

Besides the GPAI obligations in Chapter V, other provisions of the AI Act started to apply on 2 August 2025: 

- Chapter III, Section 4: obligations of providers and deployers of high-risk AI systems and other parties, 

- Chapter VII: establishment of the EU database for high-risk AI systems,

- Chapter XII: penalties with the exception of Art. 101 (fines specific to providers of general-purpose AI models),

- Article 78: confidentiality rules that European and national institutions must respect when carrying out their tasks and activities.