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General Purpose AI Model — the EU AI Act's formal term for a foundation model trained on large amounts of data and capable of performing a wide variety of tasks. The EU AI Act imposes specific obligations on GPAI model providers, including documentation requirements and cooperation with downstream deployers. If you build products on top of an API like OpenAI or Anthropic, you are a 'deployer' of a GPAI model, not a GPAI model provider — a distinction that significantly affects your compliance obligations.
Why this matters for your team
If you build on top of an API like OpenAI or Anthropic, you are a 'deployer' under the EU AI Act — not a provider. This significantly reduces your compliance burden, but you still need to document your deployment configuration and ensure your use case doesn't push the system into a high-risk category.
OpenAI's GPT-4o is a GPAI model under the EU AI Act. A company that builds a customer service chatbot using the GPT-4o API is a deployer, not a GPAI model provider.