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T12 General-Purpose AI Model Checklist

Verification required. This is a working template, not a regulator-approved form. Where it cites an article or a date, the citation comes from secondary sources or from memory of the legal text and is a pointer to check. This is not legal advice.

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Wiki controls: AI-CTRL-014, AI-CTRL-028, AI-CTRL-029. Use part A if you provide a general-purpose AI (GPAI) model and part B if you build on one. The obligation list is [Recalled] from Arts. 51 to 55. Read the text and the Commission's GPAI guidelines of 10 July 2025 [Reported]. GPAI duties have applied since 2 Aug 2025, and the AI Office gained enforcement powers on 2 Aug 2026 [Reported]. Models that were on the market before 2 Aug 2025 reportedly have until 2 Aug 2027 [Reported].

A. Provider checklist

# Obligation Status Evidence
A1 Is it a GPAI model under the guidelines? Record the reasoning
A2 Technical documentation for the AI Office and downstream providers
A3 Information for downstream providers that integrate the model
A4 Copyright compliance policy, including respect for text-and-data-mining opt-outs
A5 Public summary of training content (using the template)
A6 Authorised representative, if non-EU
A7 Open-source exemption analysis (does it apply, and are systemic-risk models excluded)
A8 Code of Practice: signed, partially signed, or an alternative demonstration (reported signatories include several large providers)

Systemic-risk models

# Obligation Status Evidence
S1 Classification (reported presumption threshold: training compute above 10^25 floating-point operations)
S2 Notify the Commission
S3 Model evaluation, including adversarial testing
S4 Assess and mitigate systemic risks
S5 Serious incident tracking and reporting to the AI Office
S6 Cybersecurity protection of the model and its infrastructure

B. Downstream checklist

For teams that integrate a GPAI model.

# Question Answer Evidence
B1 Does the model provider supply documentation and intended-use information?
B2 Does your use make you a provider of a high-risk or transparency-duty system?
B3 Have you checked the supplier's Code of Practice status?
B4 Do contracts cover model changes, deprecation and incident notice?
B5 Have you tested the model in your use case (bias, safety, accuracy, language)?
B6 Data flows and transfers (T04)
B7 Content marking and disclosure obligations (T06)
B8 Fine-tuning: did you become a provider of a new model? Record the reasoning

C. Decisions

Owner: __ Date: _ Next review (on a model version change or a guideline update): ___