GPAI Model Provider Obligations
If your AI system uses a foundation model (GPT, Claude, Gemini, Llama, etc.), KlarvoEngine automatically checks for GPAI-related obligations under Chapter V (Articles 51-56).
What Is a GPAI Model?
A general-purpose AI model is trained with large amounts of data using self-supervision at scale, displays significant generality, and can perform a wide range of tasks. The EU Commission's guidelines add a technical threshold: models trained with more than 10²³ FLOPs that generate language, images, or video.
GPAI models: GPT-4, Claude 3/4, Gemini, Llama, Mistral, DALL-E, Stable Diffusion
NOT GPAI: Weather models, protein folding, game AI, transcription-only models
Two Tiers
Tier 1 — All GPAI Providers (Article 53):
Technical documentation (Annex XI)
Downstream provider information (Annex XII)
Copyright policy
Training data summary publication
Cooperation with authorities
Tier 2 — Systemic Risk (Articles 51 + 55):
Additional obligations for models trained above 10²⁵ FLOPs:
Model evaluation with adversarial testing
Systemic risk assessment and mitigation
Serious incident reporting
Cybersecurity for model and infrastructure
Commission notification within 2 weeks
What Klarvo Users Need to Do
Most Klarvo users are DEPLOYERS, not GPAI providers. Your obligations:
Verify provider documentation — check your model provider supplied Annex XII docs
Check copyright policy — confirm provider has a published policy
Verify training data summary — check provider published this
Assess fine-tuning scope — if you fine-tuned, does your compute exceed 1/3 of original?
Document model version — record which version you use for traceability
When You Become a Provider
You become a GPAI provider if:
You fine-tune with compute exceeding 1/3 of original training
You develop a GPAI model from scratch
You place a GPAI model on the EU market for the first time
You do NOT become a provider if:
You use a model via API (you're a deployer)
You do prompt engineering or RAG
You build an AI system on top of a model (you're an AI system provider)
KlarvoEngine Detection
During classification, KlarvoEngine automatically:
Identifies if a GPAI model is mentioned in the description
Checks the model against known providers (OpenAI, Anthropic, Google, Meta, etc.)
Flags relevant GPAI obligations in your obligation list
Notes systemic risk status where known
Enforcement Timeline
GPAI obligations enforceable since August 2, 2025
GPAI fines applicable from August 2, 2026 (up to €15M or 3% turnover)
Pre-August 2025 models have until August 2, 2027 to comply
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