EU AI Office — GPAI scope guidelines + Code of Practice
Tag: S-2026-04-29-eu-ai-office-gpai
Type: report
Author(s): European Commission / EU AI Office.
Date of source: Guidelines on scope of obligations for GPAI providers, published in 24 EU official languages (referenced from late April 2026). Article 50 Code of Practice 2nd draft 5 March 2026. EU AI Continent Action Plan 9 April 2026. Code of Practice on marking and labelling working groups November 2025 – May 2026.
Date ingested: 2026-05-17
Authority weight: high — Commission / AI Office publications.
Raw file: Open Brain corpus snapshot at /_raw_sources/open-brain-2026-05-17-corpus.md.
What it claims
The European Commission / EU AI Office published Guidelines on the scope of obligations for providers of General-Purpose AI models under the AI Act, complemented by the General-Purpose AI Code of Practice. Key positions:
- GPAI provider obligations have applied since 2 August 2025.
- Full Commission enforcement, including fines, begins 2 August 2026.
- Pre-2 August 2025 GPAI models on the market have until 2 August 2027 to comply.
- Deployers / embedders of third-party GPAI models in regulated workflows must evidence upstream-provider compliance — copyright policy and training-data summary — within their own AI governance and third-party risk frameworks.
- The Code of Practice on marking and labelling of AI-generated content (Article 50 transparency) is in working-group iteration November 2025 – May 2026; guidelines are in preparation for publication Q2 2026; a November 2026 watermarking requirement is referenced for AI-generated audio, image, video, and text.
- Non-compliance risks fines up to 6% of global annual turnover.
The EU AI Continent Action Plan (9 April 2026) and an EU AI Office targeted consultation on AI energy consumption (April 2026) sit alongside this work.
Notable quotes
None captured verbatim. Direct fetch of digital-strategy.ec.europa.eu was blocked in the capture period.
What’s speculative vs. asserted
- Asserted: the 2 Aug 2025 / 2 Aug 2026 / 2 Aug 2027 dates; the 6% fine cap; the copyright policy and training-data summary requirements; the Code of Practice working-group timeline.
- Speculative: the November 2026 watermarking obligation as an enforceable date — the underlying Code of Practice was still in draft as of last capture.
Topics this feeds
- EU AI Act
- GPAI Code of Practice
- Operational Resilience and Third Party Risk — deployer obligations interact with third-party risk frameworks.
Relationships
- contradicts → S-2025-11-19-eu-digital-omnibus — disagree on whether the 2 August 2026 high-risk timeline holds; this source treats the enforcement track as firm. Both sources agree GPAI / Article 50 transparency obligations are out of scope of any delay. Status: unresolved — see EU AI Act §Tensions.
Open questions raised
- Will the Article 50 Code of Practice publish in time for the 2 August 2026 transparency date?
- How systemic-risk evaluation methodology for GPAI will be assessed in practice — methodology still being published per Paul’s 6 May 2026 capture.