The Obligations of Providers of
General-Purpose AI Models
Michael Veale1,2 and João Pedro Quintais 2
1Faculty of Laws, University College London
2Institute for Information Law, University of Amsterdam
To appear in Zanfir Fortuna, Malgieri, González Fuster and Mantelero (eds.) The Artificial Intelligence
Act — A Thematic Commentary (Hart forthcoming 2026). This version: November 2025.
During the legislative process, the EU Artificial Intelligence (AI) Act was
amended to include provisions related to general-purpose AI (GPAI) models.
These broadly relate to transparency towards downstream users and relevant
regulators, in addition to obligations connected to intellectual property. In this
paper, we provide detailed analysis of these new provisions in the context of
current technological applications and emerging trajectories, connecting them
to computing literature and practice, and the broader context of connected
and adjacent legal regimes, in particular copyright and relevant emerging case
law. We find that there are a significant number of inclarities, tensions and
contradictions both within the text, between the text and other legal regimes,
and between the text and guideline documents, such as the Code of Practice
on General-Purpose AI and recent guidelines by the European Commission.
We identify a range of issues with the scoping of the provisions which may
undermine its policy goals and create loopholes for regulatory avoidance, such
as those relating to non-commercial models, open-source models, and model
finetuning along the value chain. We find that the Code of Practice contains
significant omissions and misstatements, some of which may present a compliance
risk for an entity choosing to rely on the Code. We do not consider the provisions
on GPAI models which present a systemic risk, which are dealt with elsewhere
in the volume which this work will form a part of.
A table of contents for the paper - 47 pages long, covering legislative background, definitions, information/documentation requirements, copyright, demonstration of compliance, exclusions and concluding remarks.
New from @jpquintais.bsky.social & me: a critical and wide analysis of the Obligations of all General-Purpose AI Model providers under the EU AI Act. We give a deep ~50 page, 300 footnote treatment and find so many tensions, loopholes, inconsistencies and more.
Link: files.michae.lv/papers/Veale...
18.11.2025 13:56 — 👍 45 🔁 20 💬 2 📌 0
Are the European TDM Exceptions Applicable to GenAI Training? Despite the Three-Step Test?
Are the European TDM Exceptions Applicable to GenAI Training? Despite the Three-Step Test? By Martin Senftleben on the Kluwer Copyright Blog
legalblogs.wolterskluwer.com/copyright-bl...
01.10.2025 07:30 — 👍 1 🔁 0 💬 0 📌 0
WK Blogs | Kluwer Copyright Blog
An EU Copyright Framework for Research: Opinion of the European Copyright Society, by Caterina Sganga, Christophe Geiger, Thomas Margoni, Martin Senftleben & Mireille van Eechoud on the Kluwer Copyright Blog
legalblogs.wolterskluwer.com/copyright-bl...
04.08.2025 08:38 — 👍 3 🔁 1 💬 0 📌 0
Our summer courses have kicked off today and indeed, summer it is in Amsterdam!🌞We hope everyone will enjoy the sessions in the different courses on Copyright, Privacy and Platform Regulation. Stay cool!
@elsdebusser.bsky.social, @jpquintais.bsky.social, @jvh.bsky.social, @pjleerssen.bsky.social
30.06.2025 10:11 — 👍 4 🔁 2 💬 0 📌 0
CommonsDB Feasibility Study: Building the Future of Digital Commons – Open Future
This study outlines how CommonsDB is creating a registry of Public Domain and openly licensed works to improve legal certainty when reusing digital content.
The first part of CommonsDB Feasibility Study—by @paulk.bsky.social, @culturedoug.bsky.social, @posth.me, @jpquintais.bsky.social, @theflyinglawyer.bsky.social, and Thomas Margon—anticipates launching the first public version of the registry after summer.
Download: openfuture.eu/publication/...
24.06.2025 08:54 — 👍 5 🔁 6 💬 1 📌 0
📢 "Copyright, the AI Act and Extraterritoriality", check out the policy brief I wrote for The Lisbon Council
➡️ lisboncouncil.net/publications...
@ivir-uva.bsky.social
19.06.2025 06:21 — 👍 3 🔁 3 💬 0 📌 0
Governance of Digital Single Market Actors
"Governance of Digital Single Market Actors" published on 01 May 2025 by Edward Elgar Publishing.
📢 New publication: "A new liability paradigm for online platforms in EU copyright law"
📝 Open access here: doi.org/10.4337/9781...
📄 Also on SSRN: papers.ssrn.com/sol3/papers....
Cc: @ivir-uva.bsky.social
22.05.2025 12:05 — 👍 4 🔁 1 💬 0 📌 0
EU copyright law roundup – first trimester of 2025 - Kluwer Copyright Blog
Slightly overdue, but here comes the first roundup of 2025. The EU courts have issued just one judgment in this trimester, but to make up for it, there have been several interesting policy initiatives...
Slightly overdue, but here comes the first #roundup of 2025 which we post regularly with @jpquintais.bsky.social at the #KluwerCopyrightBlog. The EU courts have issued just one judgment in this trimester, but to make up for it, there have been several interesting policy initiatives.
14.04.2025 08:49 — 👍 1 🔁 1 💬 0 📌 0
Gikii 2025: Amsterdam CfP
GiKii 2025 – Call for Papers Institute for Information Law (IViR), University of Amsterdam (The Netherlands) 11-12 September 2025 Technology in its villain era Has technology’s slouch towards everm…
Get ready and get creative for the upcoming edition of GiKii "Technology in its villain era?" bringing together law, technology and popular culture from angles you never thought of before. Happening in Amsterdam (hybrid also possible) on 11-12/09/25!
www.gikii.org/gikii-2025-a...
11.04.2025 10:23 — 👍 9 🔁 7 💬 1 📌 1
WK estore
📘 New Book! The 4th Edition of Collective Management of Copyright and Related Rights is now out!
Co-edited by @danielgervais.bsky.social Gervais and myself, and w/ 18 chapters by leading experts on the topic
law-store.wolterskluwer.com/s/product/co...
Cc: @ivir-uva.bsky.social
25.03.2025 07:54 — 👍 6 🔁 2 💬 0 📌 0
Check out below my interview with @foliacivitatis.bsky.social on AI, copyright and music
Cc: @ivir-uva.bsky.social @algosoc.org
19.03.2025 17:02 — 👍 3 🔁 3 💬 0 📌 0
Lecturer (Assistant Prof) at King's College London, UK.
Leading the Civic and Responsible AI Lab @civicandresponsibleai.com
Socio-legal academic of data & tech on a career break
Digital rights/commons, environment, & art/culture
Normally in Scotland/Alba, often out and about
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ACELG is dedicated to the research of European Union Law in the context of the surrounding legal and political systems and wider structures of global governance. Part of the Amsterdam Law School, University of Amsterdam. https://acelg.uva.nl/
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Platform power & data rights
Empirical legal studies
Utrecht University
Senior AI Correspondent at MLex. Award-winning reporter focused on digital policy & EU affairs. Ex Euractiv. Bylines at la Repubblica & Tagesspiegel.
Head of Research Services, Delft Uni Library 🇳🇱 | Open Science 🔭 | Technology 💾 | Digital Culture and Humanities 🎨
Chief Brussels correspondent, Euractiv
Nobody knows politics and policy like we do.
www.politico.com
Law professor at UC Berkeley, cyclist, auntie.
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