Separate GPAI model duties from application-level controls: Which distinction should guide the compliance
GPAI model obligations and application-level duties are distinct; using a general-purpose model does not determine the application’s classification.
The question
An employer uses a general-purpose AI model for an internal employee-assistance chatbot. The model provider supplies model-level information, while the employer configures the chatbot for workplace tasks. Assume relevant EU AI Act obligations apply. Which distinction should guide the compliance inventory?
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- Separate GPAI model duties from application-level controls. ✓Model obligations and application responsibilities arise at different layers, so the inventory must distinguish provider and deployer roles.
- Treat the chatbot as high-risk solely because it uses GPAI.High-risk status depends on intended purpose and use, not merely on the underlying model’s general-purpose character.
- Apply only the model provider’s GPAI obligations.The employer’s configured application may create separate system or deployer responsibilities; model-level obligations do not exhaust the inventory.
- Use the commercial contract to allocate every statutory duty.Contracts can allocate practical tasks, but they do not override statutory responsibilities determined by roles and conduct.
The trap
Analyze the model layer and the deployed application separately before assigning duties. How to remember it
GPAI model obligations and application-level duties are distinct; using a general-purpose model does not determine the application’s classification.
How many of these would you get right?
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