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The European Commission has launched a targeted consultation to support the development of Guidelines for implementing the AI Act, inviting all relevant GPAI stakeholders to submit their input via a survey until May 22, 2025.
Through this multi-stakeholder consultation, the Commission aims to gather operational and practical insights from General-Purpose AI (GPAI) providers, downstream AI system developers, researchers, public authorities, and other professionals. The goal is to support the development of Guidelines that facilitate the effective enforcement of Regulation (EU) 2024/1689 (AI Act).
Why is this consultation critical?
GPAI systems present unique regulatory challenges. Their versatility enables them to perform a wide range of tasks and be embedded into countless downstream applications. This creates significant grey areas in legal qualification and compliance obligations – a complexity compounded by the rapid evolution of AI technologies.
With GPAI-specific provisions set to apply from August 2, 2025, the Commission seeks to clarify several key issues:
- Defining “GPAI”: establishing the scope of models falling under this classification.
- Providing accountability: identifying who holds responsibility in complex, layered development chains.
- Defining “placing on the market”: determining the precise moment a GPAI model is considered “placed on the market”.
- Calculating threshold estimation: defining how to measure computational resources used during model training.
- Open-source exemptions: clarifying when and how regulatory exemptions apply.
- Code of Practice: outlining the benefits and commitments of adhering to the voluntary Code.
The role of the European AI Office
The European AI Office, supported by the Joint Research Centre, will lead in drafting of these Guidelines. Although non-binding, they will serve as the Commission’s official interpretative framework for the implementaing the AI Act, especially Articles 52–55. They will be a crucial reference point for operators seeking compliance.
A central element of the consultation is the forthcoming AI Code of Practice, designed to support responsible GPAI development and use. The Commission asserts that participation in this Code will offer advantages for providers, including:
- increased trust: with non-signatories being expected to demonstrate AI Act compliance via other means, potentially with additional explanation;
- regulatory alignment: offering a structured path to meet AI Act obligations; and
- recognition of best practices: establishing operational standards at both EU and international levels.
The Code is intended to be fully aligned with the AI Act and will address key aspects such as documentation requirements, copyright risk management, and specific safeguards for models deemed to pose systemic risk (Articles 53 and 55).
What should developers and businesses know?
For organizations developing, modifying, or integrating GPAI models, this consultation is an opportunity to shape future regulatory expectations and seek clarity on their roles and responsibilities under the AI Act.
The consultation remains open until 22 May 2025, while the final Guidelines and Code of Practice are expected to be published between May and June 2025. This initiative marks a pivotal moment in the EU’s journey towards a coherent and operational AI regulatory framework. Rather than merely collecting opinions, the consultation is a participatory process – one that allows industry players to actively contribute to a future where innovation is matched by accountability. Engaging now means helping to define a legal environment built on clarity, cooperation, and mutual trust – the foundations for a trustworthy AI ecosystem in Europe.
On the same topic, you can read the article Third Draft of the General-Purpose AI Code of Practice: Key Updates and Implications for Generative AI Stakeholders. Also, you can find the latest issues of our AI Law Journal HERE.