This article is part of a series on the operational impacts of the EU AI Act. The full series can be accessed here, with the other articles in the series listed below.

If you were to read the European Commission's original AI Act proposal, published in April 2021, you would find it conspicuously devoid of references to general-purpose AI. With the benefit of hindsight, this might seem like a surprising omission. Yet, outside of the world of AI experts, few people had ever heard of general-purpose AI at the time the proposal was published.

Fast-forward to a little over one year later, OpenAI released ChatGPT to an unsuspecting public in November 2022, wowing them with its human-like, if sometimes unreliable, responses to their prompts. It quickly went viral, reportedly reaching 100 million users in just two months and becoming the fastest adopted consumer app of all time.

As a result, terms like large language models, generative AI and general-purpose AI began to enter the consciousness of European legislators, if not exactly the public consciousness. Clearly, the AI Act would need to regulate general-purpose AI, but how?

This was not an easy question to answer. The proposed law worked by placing AI systems into prohibited, high and low risk buckets to decide which rules to apply. However, by its very nature, general-purpose AI could be implemented across an unimaginably wide range of use cases that spanned the entire risk spectrum. The risks arising in any given scenario would necessarily depend on context, making it impossible to place general-purpose AI into a single risk bucket.

Consequently, Europe's legislators ultimately proposed an entirely new chapter of the AI Act dedicated specifically to regulating general-purpose AI models: Chapter V.

This article provides insight into obligations for general-purpose AI models in relation to the EU AI Act.

Top 10 operational impacts of the EU AI Act

The overview page for the series can be accessed here.

• Subject matter, definitions, key actors and scope
• Understanding and assessing risk
• Obligations on providers of high-risk AI systems
• Obligations on nonproviders of high-risk AI systems
• Obligations for general-purpose AI models
• Governance: EU and national stakeholders
• AI Assurance across the risk categories
• Post-market monitoring, information sharing and enforcement
• Regulatory implementation and application alongside EU digital strategy
• Leveraging GDPR compliance