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ChatGPT, Claude, Gemini, Mistral: the EU AI Act when your product uses a general-purpose AI model

Updated 30 September 2026 · Articles 25, 50 and 51 to 56 of Regulation (EU) 2024/1689

Obligations specific to general-purpose AI ("GPAI") models fall on their providers (OpenAI, Anthropic, Google, Mistral…) since 2 August 2025. If you integrate such a model into your product, your obligations depend mainly on what your system does: transparency, and possibly high risk.

Contents

  1. What is a general-purpose AI model?
  2. Obligations of model providers
  3. Your role when you integrate a model
  4. Your obligations in practice
  5. Models with systemic risk

1. What is a general-purpose AI model?

A model trained on large amounts of data, displaying significant generality and able to competently perform a wide range of distinct tasks: writing, code, analysis, conversation, images. Large language models from OpenAI, Anthropic, Google, Meta or Mistral are typical examples. The Regulation distinguishes the model (the technical building block) from the AI system that uses it (your chatbot, tool or application).

2. Obligations of model providers (Article 53)

Models released under a free and open-source licence benefit from exemptions, unless they present systemic risk. These obligations are supervised by the European Commission's AI Office.

3. Your role when you integrate a model

Using a model through an API does not make you a "model provider". However:

4. Your obligations in practice

A compliant model does not make your system compliant. A model provider meeting Article 53 does not answer for the use you make of it.

5. Models with systemic risk (Articles 51 and 55)

A model is presumed to present systemic risk when the compute used for its training exceeds 1025 floating-point operations (Article 51(2)), or following a Commission decision. Its providers have additional obligations: model evaluation including adversarial testing, risk mitigation, serious incident reporting, cybersecurity. These obligations sit with the model provider and do not directly add to yours.

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Sources

← EU AI Act and GDPRDigital Omnibus →