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Navigating the AI Act: the GPAI Code of Practice and Guidelines

The European Commission’s GPAI Code of Practice and complementary Guidelines clarify the scope of obligations for providers of General Purpose AI (GPAI) models that entered into force under the EU AI Act in August 2025. The voluntary Code is split into three chapters covering transparency, safety and security, and copyright, and serves to enable providers to demonstrate compliance and reduce administrative burdens. The non-binding Guidelines focus on the threshold criteria for when a model is considered a GPAI model, whether they are the provider placing it on the market, whether they qualify for exemptions, and what to expect regarding the Commission's enforcement of the obligations in the EU AI Act. Major industry platforms such as Google, Microsoft, OpenAI, and Amazon have signed up to the Code, while Meta has not, based on what it considers to be legal uncertainties for model developers and EU AI Act overreach.

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