DLA Piper provides an analysis of the new guidelines published by the European Commission for providers of general-purpose AI (GPAI) models under the EU AI Act. These guidelines, developed by the EU’s AI Office, offer practical assistance for GPAI providers to understand and meet their compliance obligations before the Act becomes fully applicable in mid‑2026. They clarify key requirements such as maintaining detailed technical documentation, providing information to downstream system providers and establishing policies that respect EU copyright law.

The guidance is presented as a checklist covering essential compliance areas. It emphasizes that providers must create and keep updated technical documentation containing specific information about training and testing processes, and must draft comprehensive information to be shared with those who integrate the GPAI model into their own AI systems. The guidelines also stress the importance of developing a policy demonstrating respect for copyright during data collection and training. This publication marks a crucial step in implementing the EU AI Act and offers clarity to developers navigating the rapidly evolving AI market.