Artificial Intelligence Policy Tracker
Legal requirement Governance and accountability European Union Partially applicable

Providers of GPAI models must notify the Commission within two weeks of meeting the systemic-risk threshold

Download: JSON · MarkdownUnder EU AI Act, Article 52(1)

Verified against the official source 26 Sep 2026 (a factual check against the official source, not a legal review or legal advice)
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Verification policy and current standing · a factual check, not legal advice.
No change recorded as of 26 Sep 2026 · official source last checked
On this page 9 sections

In brief

Providers of GPAI models must notify the Commission within two weeks of meeting the systemic-risk threshold is a legal requirement under the EU AI Act in the European Union (Article 52(1)). It applies from 2 August 2025. The record carries 2 evidence examples and mappings to 2 frameworks.

Instrument
EU AI Act
Jurisdiction
European Union
Nature
Legal requirement
Source reference
Article 52(1)
Applies from
2 August 2025
Who it binds
General-purpose AI model provider
Evidence examples
2
Framework mappings
ISO/IEC 42001:2023, NIST AI Risk Management Framework 1.0
Controls that meet it
1
Official source
Open official text
Verification
Verified against the official source 26 Sep 2026

What does it require?

A provider whose general-purpose AI model meets the Article 51(1)(a) high-impact capability condition, which is presumed once cumulative training compute exceeds 10^25 floating-point operations, must notify the Commission without delay and in any event within two weeks of the condition being met or of learning that it will be met. The notification may include arguments that the model nonetheless does not present systemic risk; the Commission decides and keeps a public list of designated models.

Practical action

Track cumulative training compute per model against the threshold and pre-draft the notification and any rebuttal arguments.

Who does it apply to?

Providers of general-purpose AI models approaching or exceeding the compute threshold, including during training.

Applies from:

Which controls meet this duty?

Satisfies: the control, operated properly, does the work the duty asks for. Supports: it contributes but the duty needs more. Each control page lists every other duty it serves, so work done once can be counted once.

  • satisfiesPolicyHead of AI safety · annual
    Frontier model safety and security framework

    Serves 9 recorded duties · evidence: Published frontier safety framework, Dangerous-capability evaluation report, Threshold notification to an authority

    Compute tracking and threshold notification are part of the framework.

Templates that cover this duty

Generated from the records. Free · no account · links emailed to your work address. This duty is cited in each file with its source reference and a link back here.

All 12 templates that cover it →

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Training compute tracking recordregister
Notification to the Commissiondocument

Framework mappings

Original editorial crosswalks. They cite clause numbers only and reproduce no standard text; confidence reflects how direct the mapping is.

See every European Union duty mapped this way →

Framework mappings table
FrameworkReferenceNoteConfidence
ISO/IEC 42001:2023Clause 4.2; Annex A.8.3Interested-party requirements and external reporting.low
NIST AI RMF 1.0GOVERN 1.1, MAP 1.1Legal requirement tracking and system context.medium

Frequently asked questions

Is this a legal requirement?

Yes. It is a legal requirement under EU AI Act (Article 52(1)).

Who must comply with this obligation?

Providers of general-purpose AI models approaching or exceeding the compute threshold, including during training.

When does this obligation apply?

It applies from 2 August 2025.

What evidence shows compliance?

A reviewer would expect: Training compute tracking record; Notification to the Commission.

Which frameworks map to this obligation?

It is mapped to ISO/IEC 42001:2023 Clause 4.2; Annex A.8.3, NIST AI Risk Management Framework 1.0 GOVERN 1.1, MAP 1.1. These are editorial crosswalks with a stated confidence, not official mappings.

Which controls satisfy this obligation?

Frontier model safety and security framework.

What should an organisation do in practice?

Track cumulative training compute per model against the threshold and pre-draft the notification and any rebuttal arguments.

Cite this record

AIPolicyTracker (2026). “Providers of GPAI models must notify the Commission within two weeks of meeting the systemic-risk threshold (EU AI Act)” [AIPT-OBL-0042, verified 26 September 2026]. https://aipolicytracker.org/id/AIPT-OBL-0042 (accessed 8 November 2026). Data licensed CC BY 4.0.

Permanent id AIPT-OBL-0042: it never changes or gets reused, and its address keeps working if this page moves.

Cite the official text alongside it: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence, Official Journal of the European Union, https://eur-lex.europa.eu/eli/reg/2024/1689/oj.

BibTeX
@misc{aipolicytracker2026_providersofgpaimodelsmus,
  author       = {{AIPolicyTracker}},
  title        = {{Providers of GPAI models must notify the Commission within two weeks of meeting the systemic-risk threshold (EU AI Act)}},
  year         = {2026},
  howpublished = {\url{https://aipolicytracker.org/obligations/eu-ai-act-art-52-systemic-risk-notification}},
  url          = {https://aipolicytracker.org/obligations/eu-ai-act-art-52-systemic-risk-notification},
  urldate      = {2026-11-08},
  note         = {Data licensed CC BY 4.0. Accessed 8 November 2026}
}

Change history

No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.

Similar obligations in other instruments

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.