Assess application-level duties: Which missing control is most | AIGP
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Assess application-level duties: Which missing control is most direct?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Easy

GPAI model compliance does not settle the lending application’s duties; the bank must assess the downstream application separately.

The question

Under the EU AI Act, assume all relevant duties apply. A bank uses a general-purpose language model to extract information from financial documents, then deploys a separate application that scores applicants for lending decisions. The GPAI provider’s model-level obligations are satisfied. The bank’s application-level risk classification, documentation, data governance, oversight, and transparency have not been assessed. Which missing control is most direct?

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  1. Treat the bank solely as a model provider
    Using a GPAI model within a downstream lending application does not automatically make the bank the upstream model provider.
  2. Assess application-level duties ✓
    The downstream lending application requires separate assessment because GPAI model compliance does not resolve the application’s high-risk system obligations.
  3. Repeat the GPAI provider’s copyright policy
    The provider’s copyright policy is a model-level obligation and does not assess the bank’s downstream lending application.
  4. Publish the model’s training summary
    A public training summary concerns certain GPAI obligations, while the unresolved facts concern the bank’s application-level duties.
The trap
Separate the model layer from the application layer; downstream use can create independent duties even when GPAI obligations are satisfied.

How to remember it

GPAI model compliance does not settle the lending application’s duties; the bank must assess the downstream application separately.

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