Maintaining technical documentation: Under the EU AI Act | AIGP
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Maintaining technical documentation: Under the EU AI Act, which obligation applies specifically to providers

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

GPAI model providers must keep technical documentation, adopt a copyright policy, and publish a training-data summary.

The question

A company releases a general-purpose AI model that many others integrate into downstream applications. Under the EU AI Act, which obligation applies specifically to providers of general-purpose AI models?

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  1. Assigning each downstream application its own CE mark before any provider may integrate the general model at all.
    Plausible but wrong: CE marking applies to certain products, not to the GPAI provider's own model obligations.
  2. Maintaining technical documentation, a copyright policy, and a sufficiently detailed summary of the training data used.
    Correct: these are core obligations the Act places on providers of general-purpose AI models.
  3. Guaranteeing the model's outputs are fully deterministic so that identical prompts always return byte-identical results.
    Wrong: determinism is not required, and AI outputs are inherently probabilistic.
  4. Obtaining prior individual authorization from the AI Office for every commercial use of the model by any customer.
    Wrong: there is no per-use authorization requirement for GPAI models.
The trap
Assuming GPAI providers must CE-mark every downstream app or guarantee deterministic outputs.

How to remember it

GPAI model providers must keep technical documentation, adopt a copyright policy, and publish a training-data summary.

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