Do I need to comply with GPAI rules if I use the ChatGPT API?

No. GPAI model obligations apply to the model provider (OpenAI). As an API user, you are a deployer. However, if you build a product on top of the API that qualifies as a high-risk AI system, you become the provider of that system.

What is 'systemic risk' in GPAI?

The EU AI Act defines systemic risk as the potential for large-scale negative impacts on public health, safety, fundamental rights, or the environment. The current threshold is models trained with computational resources exceeding 10^25 FLOPs.

Quick answer

General-purpose AI model obligations fall on providers (OpenAI, Anthropic, Microsoft), not on business users. As a user, you benefit from provider compliance but have no direct GPAI obligations.

Updated June 2026 · MmowW AI Compliance

EU AI Act and General-Purpose AI: What ChatGPT, Claude, and Copilot Must Do

What General-Purpose AI Means

The EU AI Act creates a specific category for general-purpose AI (GPAI) models — AI models trained on broad data that can perform a wide range of tasks. ChatGPT, Claude, Gemini, and Copilot all qualify.

GPAI obligations under Articles 51-55 apply to model providers, not business users. If you use ChatGPT in your business, OpenAI bears the GPAI compliance burden — not you.

Provider Obligations for GPAI

All GPAI providers must: maintain technical documentation, provide information to downstream deployers, comply with EU copyright law, and publish a sufficiently detailed summary of training data.

GPAI models with systemic risk (roughly defined as models trained with more than 10^25 FLOPs) face additional obligations: model evaluation, adversarial testing, serious incident tracking and reporting, and adequate cybersecurity protections. Currently, this likely includes GPT-4, Claude 3.5/4, and Gemini Ultra.

What This Means for Business Users

As a business user of GPAI tools, you do not have direct GPAI obligations. Your obligations remain as a deployer (Articles 26-27) and under general AI literacy (Article 4).

However, GPAI transparency requirements benefit you: providers must give you enough information to understand the model's capabilities, limitations, and risks. Use this information to inform your AI literacy training and risk assessments.

Check your AI compliance readiness — free.

Take the Readiness Check 3 minutes · 10 questions · no signup required

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.