EU GPAI Regulations Now in Effect, Enforcement to Follow Next Year

Back in February, I wrote about the first provisions of the EU AI Act coming into force. Now we’ve hit another major milestone in the law’s phase-in. Requirements covering General Purpose AI (GPAI) became effective on August 2nd. However, despite these provisions officially phasing in, the State’s enforcement powers do not become active until next year. Debevoise & Plimpton explains in a recent memo:

“The European Commission’s GPAI model enforcement powers under the EU AI Act do not come into force until 2 August 2026. These include the powers to request information about or conduct evaluations of GPAI models, require GPAI model providers to take certain measures to comply with the Act, restrict or remove the GPAI model from the EU market, and impose fines of up to the higher of 3% of global annual turnover or EUR 15 million.”

European regulators are taking the next year to prepare. The memo notes that while EU-level regulators are largely ready for enforcement, some member states are still preparing. The EU published guidance on GPAI compliance last month, giving companies clarity on how regulators will interpret the law. However, the business community is largely unhappy with the EU AI Act’s limitations, and the EU is planning a “digital simplification package” that will be proposed by the EU Commission later this year. The contents of that package could drastically reshape the EU AI Act, meaning that some provisions may never make it to the enforcement deadline.