Starting 2 August 2025, Regulation (EU) 2024/1689 (AI Act) will mandate that providers of general-purpose AI (GPAI) models — those AI models that display significant generality and are capable of competently performing a wide range of distinct tasks — on the EU market comply with specific obligations.

All GPAI model providers must prepare technical documentation, a copyright policy, and a detailed summary of the training content. Non-EU providers must designate an EU representative. Providers of GPAI models that pose systemic risks must conduct risk assessments, implement risk-mitigation measures, report serious incidents, and ensure cybersecurity.

To demonstrate compliance, providers may rely on codes of practice. The European Commission received the final version of the GPAI Code of Practice on 10 July 2025. It is expected that the Member States and the European Commission shall endorse the Code in August 2025.

Transitional Period: GPAI models that have been placed on the market before 2 August 2025 must comply with the AI Act by 2 August 2027. As regards new models, the applicable rules shall become enforceable by the European Commission as of 2 August 2026.

In addition, by 2 August 2025, Member States should designate national competent authorities and establish rules for penalties. Bulgaria has yet to designate its authorities and adopt national implementing legislation. At this point, only the authorities protecting fundamental rights have been identified.

Feel free to reach out to Violetta Kunze, Ralitsa Gougleva and Georgi Sulev, part of #DGKV’s AI Governance Group, for more information.