Question 1

Are GPAI obligations already in force?

Accepted Answer

Yes. GPAI provider obligations under Articles 53–55 of the EU AI Act apply from August 2, 2025 — one year after the regulation entered into force. This covers transparency obligations, Annex XI technical documentation, model evaluation requirements, and the systemic risk framework for models with significant capabilities.

Question 2

What does Annex XI require for GPAI models?

Accepted Answer

Annex XI requires GPAI providers to maintain technical documentation including: model architecture and training process description, training data sources and data governance, compute resources used, testing and evaluation methodology, known limitations and failure modes, measures taken to reduce risks, and instructions for downstream providers. This documentation must be kept up to date and made available to the AI Office on request.

Question 3

What is systemic risk and how is it assessed?

Accepted Answer

Systemic risk under the EU AI Act applies to GPAI models with high-impact capabilities. The primary indicator is training compute: models trained using more than 10^25 floating-point operations (FLOPs) are presumed to present systemic risk. Additional criteria include frontier capability benchmarks, widespread deployment across high-risk sectors, and potential for significant societal impact. Models meeting these thresholds have additional obligations under Article 55 including adversarial testing and incident reporting.

Question 4

What is a model card and is it required under the EU AI Act?

Accepted Answer

Model cards are structured documents describing a model's purpose, capabilities, limitations, and evaluation results. While the EU AI Act does not use the term 'model card', the Annex XI technical documentation requirements are functionally equivalent. Scanara's GPAI module generates Annex XI-aligned documentation from model metadata, training logs, and evaluation results.

Question 5

Does the GPAI module cover open-weight models?

Accepted Answer

The EU AI Act has specific provisions for GPAI providers releasing models under open-source or open-weight licences. Open-weight models with fewer than 10^25 training FLOPs benefit from reduced obligations — primarily the Annex XI documentation and a copyright policy. Open-weight models that present systemic risk retain full Article 55 obligations. Scanara's GPAI module supports both obligation sets.

EU AI Act for GPAI Providers — Scanara

GPAI obligations are already in force — August 2025

What GPAI providers are facing

Obligations already in force

Annex XI documentation is complex

Systemic risk classification is unclear

What Scanara's GPAI module covers

Annex XI compliance check

Model card automation

Systemic risk assessment

Downstream transparency package

Frequently asked questions

Start your GPAI compliance program

How Scanara Helps