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Publication of the code of practice for general purpose AI models

On 10 July 2025, the code of practice (“Code”) [1] for general purpose artificial intelligence models (“GPAI models”) was published. Provided for in Article 56 of Regulation 2024/1689 on Artificial Intelligence (“AI Act”), the Code forms part of the regulation’s phased implementation and is intended to help GPAI model providers comply with their obligations, in particular those set out in Article 53 of the AI Act.

Compliance with the Code will allow GPAI model providers to demonstrate conformity with the AI Act while reducing their administrative burden.

The Code is structured around three chapters, which constitute the essential pillars of GPAI model compliance :

  • the first chapter, on transparency, sets out three measures enabling GPAI model providers to meet the transparency obligations in Article 53(1)(a) and (b) AI Act :
    • Measure 1.1 – Drawing up and keeping up-to-date model documentation (a template of which is annexed to the Code) ;
    • Measure 1.2 – Providing relevant information, notably by publishing on the website of the GPAI model provider, contact details that allow the AI Office and downstream providers to request access to the information contained in the GPAI documentation ;
    • Measure 1.3 – Ensuring quality, integrity, and security of information documented by the GPAI model provider.
  • the second chapter, on copyright, addresses the obligations in Article 53(1)(c) AI Act which provide that GPAI model providers have to establish a policy ensuring compliance with Union copyright law. This chapter therefore provides for measures relating to the following aspects :
    • Measure 1.1 – Draw up, keep up-to-date and implement a copyright policy ;
    • Measure 1.2 – Reproduce and extract only lawfully accessible copyright-protected content when crawling the World Wide Web ;
    • Measure 1.3 – Identify and comply with rights reservations when crawling the World Wide Web ;
    • Measure 1.4 – Mitigate the risk of copyright-infringing outputs ;
    • Measure 1.5 – Designate a point of contact and enable the lodging of complaints.
  • the third chapter, on safety and security, is intended for GPIA model providers that pose a systemic risk. It provides for a set of measures enabling them to comply with the obligations set out, in particular, in Articles 55(1) and 56(5) of the RIA.

The Code now awaits approval by the Member States and the Commission and will be supplemented by Commission guidelines clarifying certain concepts related to GPAI models.