The Bottom Line: The EU Commission has published guidelines for GPAI models establishing a computational threshold of 10²³ FLOPs as a classification criterion. Models exceeding 10²⁵ FLOPs are deemed high-risk and subject to extensive reporting obligations, documentation, and risk assessment requirements. Providers can contest determinations and have reassessment rights.
On 18 July 2025, the European Commission published draft guidelines clarifying key provisions of the EU AI Act for general-purpose AI (GPAI) models. Among other things, the guidelines define a computational threshold of 10²³ FLOPs, thereby establishing a clear distinction for AI systems with broad applicability.
The new guidelines specify the statutory definition of GPAI models through several thresholds and criteria:
**Computational Threshold and Functional Generality**
A GPAI model is defined as a system trained with more than 10²³ floating point operations and capable of generating content in the areas of language (text/audio), text-to-image, or text-to-video. Computational power is understood as a combined measure of model size and training data volume. A model with approximately one billion parameters trained on extensive datasets typically meets this threshold. Specialized models lacking broad applicability are, however, excluded from this classification.
**Lifecycle Obligations**
Once a model is classified as GPAI, obligations under the AI Act apply throughout the entire development process—from pre-training through market modifications. These include comprehensive documentation requirements, publication of training data summaries according to EU Office templates, and regulations ensuring copyright compliance.
**Systemic Risk and High-Risk Classification**
Models with at least 10²⁵ FLOPs are considered potentially high-risk and may be classified as systemically risky. This triggers extensive additional requirements, including risk assessments, cybersecurity measures, and reporting obligations for critical incidents.
**Reporting Obligations and Review Processes**
Providers must notify the Commission within two weeks if they reach or foreseeably will reach the 10²⁵ FLOPs threshold. They may contest this classification by submitting robust evidence that the model does not present a systemic risk. Reassessment requests are possible after six months and again after an additional six months. Should the basis of the contestation have materially changed or been incomplete, new notification is required.