The EU AI Act makes a strict legal distinction between upstream General Purpose AI models and downstream AI systems. A General Purpose AI model is a foundational software model trained on vast data with broad generality, such as a base large language model. In contrast, a downstream AI system is an end-user application that incorporates or wraps that model for a specific operational purpose.

Providers of standard General Purpose AI models must meet four basic statutory duties. First, maintain technical documentation detailing model architecture and training. Second, share integration information with downstream providers incorporating the model. Third, put in place a policy to comply with EU copyright law. Fourth, publish a detailed public summary of the training data used.