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2 August 2025 was an important deadline under the EU AI Act: obligations for providers of general-purpose AI (GPAI) models entered into force, provided the model is placed on the market on or after this date.

The European Commission and EU AI Office have been gearing up for this deadline with recently released Guidelines for providers of general-purpose AI models and a final General-Purpose AI Code of Practice. The Code was subject to the Commission and the AI Board assessing its adequacy, and the Commission confirmed the Code’s formal approval on 1 August.

The Guidelines provide an interpretative framework for understanding the obligations of providers of general-purpose AI models, and the Code offers specific measures suggested by the Commission that providers can implement to demonstrate that they meet these obligations.

Click here to understand the practical impact and concrete actions to take now, and for more detail on the Guidelines and Code.

We would like to thank our colleagues Kathy Harford, Helen Davenport and Karen Battersby for their contributions to this article.

Author

José María Méndez is head of the Intellectual Property, Tech and Media department at Baker McKenzie Madrid and head of the EMEA IPTech practice. Mr. Méndez is recognized as a leader in his field by the most prestigious legal directories. According to Chambers Europe, José María Méndez "was born for copyright law" and “his style is oriented to being pragmatic and offers clear and easy to implement solutions." Jose María is hailed as an “expert in media and production” and considered “the king in audiovisual matters.” Clients describe Jose María as “very specialized and has unsurpassed knowledge of the audio-visual industry.”

Author

John is a media and technology lawyer and is currently EMEA Head of Regulatory at Baker McKenzie. He is a Partner in Baker McKenzie's London office, having spent 12 months in the San Francisco office in 2018. John’s practice has three main strands: (1) technology and content regulation; (2) product counselling on new technologies; and (3) copyright and digital media. Most of his time is currently spent advising clients on the EU DSA and UK OSA, including representing clients on RFIs and Investigations in front of the European Commission and Ofcom. He also regularly helps clients launch new AI products, navigating risk and regulation (like the EU AI Act). He is ranked in Chambers UK and Legal500 across various Technology and Media categories. Managing IP ranks him as a "rising star" for copyright. He is also included in Thomson Reuters "Stand-out Lawyers" rankings, and Best Lawyers ranks him as "one to watch" for TMT. In 2020 John was elected to TechUK's Data Analytics and AI Leadership Committee.