Publication of the General-Purpose AI Code of Practice and Guidelines for providers of General-Purpose AI models

The European Commission has recently released a voluntary General-Purpose AI Code of Practice, designed to help industry comply with AI Act’s obligations for providers of general-purpose AI (GPAI) models. 

The Code was developed by independent experts through a multi-stakeholder process, launched in July 2024, involving over 1400 participants from industry, academia, civil society, rightsholders, and EU Member States represented in the AI Board.

The Code is divided into three separate chapters: (1) Transparency[1] and (2) Copyright[2], both applicable to all GPAI model providers, and (3) Safety and Security[3], relevant only to limited number of providers of advanced models with systemic risk.

The Code is not legally binding and does not impose new obligations or additional regulatory burden. It serves as guidance for GPAI model providers to meet their existing obligations under the AI Act.

In the next weeks, Member States and the Commission will assess the adequacy of the Code. Once the Code is endorsed, GPAI model providers who voluntarily sign it can show their compliance with the AI Act by adhering to the Code. This will offer a simple and transparent way to demonstrate compliance with the AI Act, reduce administrative burden and give more legal certainty. 

In addition, the European Commission has issued guidelines[4] to clarify the scope of the obligations for providers of general-purpose AI models under the AI Act. These obligations enter into application on 2 August 2025. 

The guidelines complement the GPAI Code of Practice and explain how the Commission interprets key terms in the AI Act, specifically in relation to the obligations for providers of GPAI models. The guidelines help actors along the AI value chain identifying whether a model qualifies as a GPAI model, whether they are to be considered as providers placing the model on the market, whether they qualify for exemptions, and what to expect regarding the Commission’s enforcement of the obligations in the AI Act. 

The Guidelines are not legally binding. However, they set out the Commission’s interpretation and application of the AI Act, on which it will base its enforcement action. 

For additional information, you can consult the European Commission website via the links hereafter: GPAI Code of Practice and Guidelines for providers of GPAI models.

Any company or person interested in sharing its opinion or questions with the Chamber of Commerce on the above-mentioned topics is invited to contact juridique@cc.lu.