Clifford Chance

On 18 July, the European Commission published its guidelines to clarify the AI Act’s requirements for providers of GPAI models (GPAI Guidelines). These came just over one week after the publication of the Code of Practice for GPAI models. On 24 July, the European Commission also published the template for the public summary to be drawn up regarding the content used for GPAI model training. Additionally, on 1 August, the European Commission and the AI Board published their assessments confirming the 'adequacy' of the GPAI Code of Practice.

Whilst non-binding, the GPAI Guidelines are helpful in framing the impact of the AI Act for model providers and they provide useful clarifications. However, gaps and important questions remain.

In this publication, we share insights on a selection of items regarding the GPAI Guidelines, including areas where executive decisions and action may be needed pending potential future developments. We also include a few pointers on the GPAI Code of Practice and a brief overview of the GPAI training summary template.

This is a crucial moment to understand the rules for GPAI models and the impact of all these documents, as requirements for GPAI models start to apply 2 August 2025.