Do the GPAI rules apply to you?
Article 53 applies if you place a general-purpose AI model on the EU market. Building a product on top of someone else's model does not make you a provider — fine-tuning and releasing a model may.
What the law requires
Providers of general-purpose AI models must keep technical documentation of the model and its training and testing, make information available to downstream providers integrating it, put a policy in place to comply with EU copyright law, and publish a sufficiently detailed summary of the content used for training.
Models presenting systemic risk carry additional Art. 55 obligations: model evaluation, adversarial testing, incident tracking and reporting, and cybersecurity protection.
Most website operators are deployers, not providers. Using an API to build a product does not make you a GPAI provider. Fine-tuning a model and releasing it, or distributing model weights, can.
Open-source models released under a free and open licence have partial exemptions, though not from the copyright policy and training-data summary where the model presents systemic risk.
What our scanner looks for
- Signals that you publish or distribute AI models rather than only consume them — model cards, weight downloads, model documentation, hosted-model marketing.
- Whether a copyright policy and training-data summary are published where those signals appear.
- This check is informational. It flags that a heavier obligation set may apply so it can be assessed properly, rather than asserting that it does.
How to fix it
- 1First establish your role. Provider, deployer, distributor and importer carry different duties, and most site operators are deployers.
- 2If you are a provider: publish a training-data summary using the AI Office template, document the model, and put a copyright compliance policy in place.
- 3If you are a deployer: these obligations do not apply to you, but you should obtain the downstream documentation your model provider owes you and keep it.
Deadlines and penalties
GPAI obligations have applied since 2 August 2025 — a year before the Art. 50 transparency duties. Enforcement for GPAI sits with the Commission's AI Office, unlike Art. 50, which is enforced by national market surveillance authorities.
Free, no account needed. We'll show you every page where this applies, with the evidence.
Common questions
We fine-tuned an open model and offer it via API. Are we a provider?
Quite possibly. Fine-tuning and placing the result on the market can make you a provider of that model, with obligations scoped to your modification. This is a question worth taking to a lawyer rather than resolving from a scan.
We only call the OpenAI API. Does Article 53 apply?
No. You are a deployer of a system built on someone else's model. Article 50 transparency duties still apply to what your users interact with.
This page describes technical indicators and the obligations they relate to. It is not legal advice. A website scan detects indicators, not legal compliance — which is why our reports say “no issues detected” and never “compliant”.