General-Purpose AI Models: How ChatGPT and Similar Tools Are Regulated

What Are General-Purpose AI Models

General-purpose AI models are AI systems trained on broad data that can be used for a wide range of tasks — they're not designed for just one purpose. ChatGPT, Claude, Gemini, and similar tools are examples. You can use them for writing, analysis, coding, customer service, and many other tasks without modifying the underlying model.

The EU AI Act recognizes these models as a distinct category because they don't fit neatly into the risk-based classification. They're not inherently high-risk or low-risk — it depends on how they're used. So the law created specific rules for GPAI model providers.

What GPAI Model Providers Must Do

Providers of GPAI models must maintain and make available technical documentation, provide information and documentation to downstream providers, put in place a copyright policy, and publish a summary of the training data used. These obligations apply from August 2025.

For models with "systemic risk" — very powerful models that could have broad societal impact — there are additional requirements including adversarial testing, serious incident tracking and reporting, cybersecurity protections, and energy efficiency reporting.

What This Means for Your Business

If you're using GPAI tools like ChatGPT in your business, these rules primarily affect your AI provider, not you directly. However, they benefit you because they mean your provider must be more transparent about how their model works, what data it was trained on, and what its limitations are.

You should use this increased transparency to your advantage. Ask your GPAI provider for their technical documentation. Understand the model's limitations. Make sure your use of the model aligns with its intended capabilities.

The Downstream Chain

Many businesses use GPAI models through intermediary products — for example, a customer service tool built on top of GPT-4. In this case, both the GPAI model provider and the downstream provider have obligations. As the end user, you should ensure both your direct vendor and the underlying GPAI provider are compliant. Ask your vendor about the GPAI model powering their product and what compliance measures are in place.

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements change frequently — verify current rules with official sources. Built by Sawai Gyoseishoshi Office, Hiroshima, Japan.