Just when you thought the AI Act could not get any more bureaucratic, the European Commission has released its latest masterstroke: Guidelines on the Scope of Obligations for General-Purpose AI Models. Think of it as a 30‑plus page manual explaining how to interpret the already complex legal text of the AI Act, which itself is barely a year old. And yes, there is now an official “guideline package” that will sit alongside the already mandatory template for training data disclosures and the code of practice for AI providers. We have entered the age of regulation of regulation.

A Rulebook to Tell You If You’re in the Rulebook

The Commission’s starting point: before you can comply, you must first determine whether you are even covered. Sounds simple? Not quite. You are “in scope” if your AI model:

Unless, of course, the Commission decides otherwise. That means training compute, a metric very few people outside hyperscale AI labs can even estimate accurately, has become the new bureaucratic gatekeeper. If you are over the threshold, welcome to the paperwork.

The “Systemic Risk” Club

Cross the higher 10²⁵ FLOPs barrier and your model is presumed to have “systemic risk”.
This is Brussels‑speak for your AI is now scary enough to require extra hoops:

You must even notify the Commission before your model is finished if you think it will cross the limit. Planning to use a big training run? Better tell Brussels in advance. Yes, really.

Providers, Modifiers, and Everyone in Between

The guidelines spend pages defining who counts as a “provider”:

There is even an indicative threshold for when fine‑tuning makes you a new provider: more than a third of the original model’s training compute. The EU has officially quantified when a derivative model becomes yours, and your problem.

Open Source… But Not Too Open

The AI Act famously promised exemptions for open‑source models. The guidelines clarify:

And if your open model has “systemic risk”? No exemptions. You are back in the compliance game.

A Glimpse of the Future

The AI Office, a new EU entity, will enforce all this from 2 August 2025. Compliance will be judged not only on the law, but also on these guidelines. And the guidelines themselves? Non‑binding… except they are the very framework the Commission will use to decide enforcement. This is the European regulatory machine at full throttle:

  1. Write a sweeping law.
  2. Create a dense template for disclosures.
  3. Draft a “code of practice” for good measure.
  4. Add a “guideline” to interpret the law.
  5. Enforce the guideline as if it were the law.

Somewhere in this process, innovation is expected to flourish.