The EU AI Act: general-purpose AI (GPAI) models and the systemic-risk tier
The EU AI Act regulates general-purpose AI at the model level, separately from the risk tiers that apply to systems. That distinction — model rules versus system rules — is the core of this topic.
Why this matters for the AIGP exam
GPAI is a conceptual shift the exam tests directly: obligations that attach to the model itself, whoever later builds on it, on top of whatever tier a downstream system lands in.
The essentials
- All GPAI providers owe four things: technical documentation of the model, information to downstream providers who build on it, a policy for complying with EU copyright law (including honouring text-and-data-mining opt-outs), and a public summary of the content used for training.
- The systemic-risk tier. Models with high-impact capabilities carry extra duties. Training compute above 1025 floating-point operations creates a presumption of systemic risk, and the Commission can also designate models directly.
- Systemic-risk providers additionally owe: model evaluations including adversarial testing, assessment and mitigation of systemic risks, serious-incident reporting, and cybersecurity protection for the model and its weights.
- Open-source relief is partial. Freely licensed open models are exempt from some baseline duties — but the exemption falls away entirely at the systemic-risk tier.
- Downstream stacking. A company that builds a hiring tool on a GPAI model is a provider of a high-risk system; the model provider's GPAI duties continue alongside.
What the exam asks
Separate model-level from system-level obligations in a scenario, and identify what changes once a model crosses the systemic-risk threshold.
Going deeper
This page is the condensed version. The full topic — with the detail above expanded and practice questions attached — is in the app, inside Domain II. Domain I, a quarter of the course, is free to try first.
Back to the AIGP study guide.
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