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EU AI Legislation: Commission Seeks to Reinstate Tiered Framework, Focusing on General Purpose AI

What was reported

The European Commission proposed a compromise for the EU's AI law, focusing on general-purpose AI (GPAI) models and introducing codes of practice for models with systemic risks. This proposal aims to address disagreements among EU countries about regulating powerful foundation models like GPT-4. The compromise maintains a tiered approach, differentiates between GPAI models and systems, and suggests obligations for models with systemic risks, including transparency requirements and risk mitigation measures. This is part of the final negotiation phase for the landmark AI Act.

What has happened since this was written

This piece was published on 28 November 2023, while the Regulation was still moving through the EU legislative process, so it describes a draft. Everything in the table below has happened since. Any article number, penalty figure or date in the text above should be read against the adopted and amended Regulation rather than relied on.

The Regulation’s progress since 28 November 2023
DateWhat happenedStatus
1 Aug 2024The Regulation enters into forceIn force
2 Feb 2025Prohibited practices and AI literacy applyIn force
2 Aug 2025General-purpose AI model obligations applyIn force
2 Aug 2026Transparency obligations and the general application dateIn force
2 Dec 2026Two new prohibitions and the legacy marking deadlineUpcoming
2 Dec 2027Annex III high-risk obligations applyUpcoming
2 Aug 2028Annex I product-safety high-risk obligations applyUpcoming
2 Aug 2030Legacy large-scale IT systems must complyUpcoming

The text was also amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI, which deferred the high-risk deadlines, added two prohibited practices, softened the Article 4 AI literacy duty and gave the AI Office direct enforcement powers.

For the position under the current text, start with the implementation timeline, the compliance checklist or our analysis. The full legal text is at the Act explorer.