Check applicable exception conditions: What is the most defensible next step?
Open licensing can matter conditionally, but it is not a blanket exemption; unresolved systemic-risk and training obligations require analysis.
The question
Assume EU AI Act general-purpose AI obligations apply to an internal employee-assistance model released under an open license. The provider claims the license removes every GPAI obligation, while the model’s systemic-risk status and training-content records remain unresolved. What is the most defensible next step?
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- Apply every high-risk system duty to the model.General-purpose model obligations differ from high-risk system obligations, and classification cannot be inferred solely from internal deployment.
- Treat open licensing as a complete exemption.The evidence expressly rejects a blanket exemption; open licensing does not automatically remove every general-purpose AI obligation.
- Ignore training-content records because employees are the only users.Internal users do not by themselves resolve model obligations or eliminate the need to examine applicable training-content requirements.
- Check applicable exception conditions. ✓Open licensing may create relevant exceptions, but applicability depends on conditions and does not automatically resolve systemic-risk or other duties.
The trap
Treat open licensing as a condition to analyze, not as a universal exemption from model duties. How to remember it
Open licensing can matter conditionally, but it is not a blanket exemption; unresolved systemic-risk and training obligations require analysis.
How many of these would you get right?
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