Which Requirements Apply to GPAI Models?

GPAI models (see Sect. 1.2.6 ), such as large generative AI models (‘genAI’) and large language models (‘LLMs’), are subject to special provisions of the AI Act. AI models can be implemented for a variety of different possible use cases, but they are not in themselves AI systems (Recital 97). Thus, they cannot be considered as high-risk under the AI Act. If they are subjected to further fine-tuning and/or supplemented with user interfaces, they can also be used in high-risk AI systems. Therefore, the legislator has decided to impose special obligations on providers of GPAI models to address the specific risks connected to GPAI models special combination of significant capacities and unexpected use cases.