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European Union: General-purpose AI obligations under the EU AI Act kick in from 2 August 2025

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In brief

2 August 2025 was an important deadline under the EU AI Act: obligations for providers of general-purpose AI (GPAI) models entered into force, provided the model is placed on the market on or after this date.

The European Commission and EU AI Office have been gearing up for this deadline with recently released Guidelines for providers of general-purpose AI models (the Guidelines) and a final General-Purpose AI Code of Practice (the Code). The Code was subject to the Commission and the AI Board assessing its adequacy. The Commission confirmed the Code’s formal approval on 1 August.

The Guidelines provide an interpretative framework for understanding the obligations of providers of general-purpose AI models, and the Code offers specific measures suggested by the Commission that providers can implement to demonstrate that they meet these obligations.

Kathy Harford, Lead Knowledge Lawyer, Helen Davenport, Lead Knowledge Lawyer – Technology, and Karen Battersby, Director of Knowledge for Sectors and Clients, contributed to this legal update.

Click here to read the full alert.

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José María Méndez is head of the Intellectual Property, Tech and Media department at Baker McKenzie Madrid and head of the EMEA IPTech practice.
Mr. Méndez is recognized as a leader in his field by the most prestigious legal directories. According to Chambers Europe, José María Méndez "was born for copyright law" and “his style is oriented to being pragmatic and offers clear and easy to implement solutions." Jose María is hailed as an “expert in media and production” and considered “the king in audiovisual matters.” Clients describe Jose María as “very specialized and has unsurpassed knowledge of the audio-visual industry.”

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John is a media and technology lawyer in Baker McKenzie's IP and Technology team. He is ranked as a “rising star” for TMT, and recognised as a key lawyer for Media and Entertainment in the UK by Legal 500. In 2020 John was elected to TechUK’s Data Analytics and AI Leadership Committee.
His practice encompasses a broad range of both contentious and non-contentious aspects of IP, Technology and Commercial law, with a particular focus on copyright, digital media, and new technologies. John writes regularly on these topics and his chapter (with Ben Allgrove), “Enforcement in a digital context: intermediary liability,” was published in Tanya Aplin (Ed.) Research Handbook on Intellectual Property and Digital Technologies in January 2020. John qualified in 2013 and is based in the London office, having spent 2018 in the San Francisco office. John is heavily involved in the Firm’s tech-focused pro bono work, as well as its social mobility initiatives.

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