Modifying AI Under the EU AI Act: Lessons from Practice on Classification and Compliance

AI Act · 11 months ago · 34

Legal compliance professionals explain how organizations modifying AI systems or general-purpose AI models may become providers under the EU AI Act, triggering higher compliance burdens and regulatory obligations. The European Commission set a one-third computing power threshold to distinguish substantial from insubstantial modifications, with GPAI model provider obligations taking effect on 2 August 2025. Organizations must properly assess modifications to determine compliance responsibilities, though vague definitions and insufficient vendor transparency create ongoing practical challenges in implementation.