GPAI evidence pack Article 53 and 55 records

Keep a model record separate from product-feature records. Article 53 applies to GPAI model providers; using a supplier's model does not by itself make your organisation that model's provider.

Record whether you originally supply the model, supply a modified or fine-tuned model, or only integrate it into a system. Keep the version, release and EU market dates, distribution, licence, dependencies, relevant authorised-representative status and authenticity evidence.

Chapter V duties apply to models placed on the market from 2 August 2025. Providers of older models have until 2 August 2027 to comply. Commission enforcement powers began to apply on 2 August 2026. Keep market-placement evidence for each model version.

Article 53(1)(a) requires current model documentation, including training, testing and evaluation results. The AI Office and national competent authorities can request it.

Use Annex XI as the minimum contents list. Include intended tasks and integration contexts, acceptable use, release and distribution, architecture and parameters, input/output types and formats, licence, development process, data sources and preparation, training/testing/validation data, compute, training time, and known or estimated energy use.

The checklist below adds ownership and update details. Treat those fields as practical record-management advice; check the legal duty and any Article 53(2) exception separately.

Under Article 53(1)(b), providers must prepare, maintain and make information available to companies intending to integrate the model into their AI systems.

Use Annex XII to explain capabilities, limitations and integration requirements so those companies can meet their own duties. Include technical integration methods, input/output constraints, licence, acceptable-use policy and data-source information.

Article 53(1)(c) requires a policy for EU copyright and related-rights law, including identifying and respecting rights reservations under Directive (EU) 2019/790 Article 4(3). These reservations tell users that a rightsholder reserves the relevant text-and-data-mining rights.

For providers using the voluntary GPAI Code, its Copyright Chapter sets commitments on the policy, responsibilities, web-crawler and rights-reservation controls, and measures against infringing outputs. Keep the evidence for the approach you use.

Article 53(1)(d) separately requires a sufficiently detailed public training-content summary using the AI Office template. Keep internal copyright records and public-summary records distinct; the checklist below covers both.

Article 55 adds duties for GPAI models classified or designated as having systemic risk. Maintain these records alongside the Article 53 and 54 records so their applicability is clear.

Training compute above 10^25 floating-point operations creates a presumption of high-impact capabilities. The Commission can also designate a model using Annex XIII criteria. Notify the Commission without delay and within two weeks after meeting the high-impact condition or learning it will be met.

Keep the compute method, assumptions, threshold date, notification and any reasoned argument against systemic-risk status. Add model evaluations, documented adversarial testing, EU-level systemic-risk assessment and mitigation, serious incidents, corrective measures, and cybersecurity for the model and its physical infrastructure.

Under Article 55(1)(c), track, document and report relevant serious-incident information and possible corrective measures without undue delay to the AI Office and, as appropriate, national competent authorities.

Give each required record an owner, evidence link and update trigger. Mark whether it is for authorities, integrating providers, public release or internal use.

Before claiming Article 55 readiness, check the added evaluation, mitigation, incident and cybersecurity records. Before relying on an open-source exception, document the licence and public access to parameters and architecture information, and check systemic-risk status.

A qualifying free and open-source model is exempt from Article 53(1)(a) and (b) technical and integration-documentation duties under Article 53(2). Copyright-policy and public-summary duties remain. Article 54(6) separately exempts a qualifying model from the authorised-representative duty. Neither exception applies to a model with systemic risk.