EU AI Act Guide

EU AI Act GPAI models

GPAI model exposure should be separated from ordinary deployment exposure. Companies need to understand whether they provide, integrate, modify or rely on a general-purpose AI model in an EU-facing workflow.

Operational information, not legal advice.

Autonomy control model

EU AI Act GPAI Models

1

Autonomy scope

Clarify whether the system only assists or can plan, call tools, act, adapt or escalate.

2

Tool access

Map which APIs, data sources, workflows and external actions the system can reach.

3

Human control

Define where review, approval, override and shutdown must remain possible.

4

Traceability

Keep prompts, actions, outputs and proof signals reviewable after execution.

Autonomy control

Autonomy scope, tool access, human control and traceability define whether agentic AI remains governable.

Direct answer

GPAI model exposure must be separated from deployment exposure.

General-purpose AI model questions are different from ordinary use-case readiness. A company should clarify whether it provides, modifies, integrates or merely uses a GPAI model before deciding which documentation and governance work matters.

For the next layer, compare provider vs deployer roles, review high-risk AI system signals, or start with an EU AI Act risk assessment.

Decision criteria

What changes the analysis

  • The company provides or distributes a general-purpose AI model.
  • The company modifies or fine-tunes a model in a way that changes responsibility.
  • The model is embedded into an EU-facing product or workflow.
  • Downstream users rely on the model in sensitive or regulated contexts.

First inspection

What to clarify first

  1. 01Model source and modification level.
  2. 02Provider, integrator and deployer roles.
  3. 03EU-facing product or workflow context.
  4. 04Documentation available from upstream providers.

This page provides operational information for AI governance readiness. It is not legal advice.