GPAI and transparency: Chapter V and Article 50 without the noise

Teams often conflate general-purpose AI (GPAI) model rules with AI system transparency rules. The EU AI Act separates them: Chapter V addresses GPAI models; Article 50 addresses certain systems that interact with people or generate synthetic content.

GPAI models (Chapter V)

A GPAI model is trained on broad data at scale and can be adapted to a wide range of distinct tasks. Providers of such models face obligations oriented around:

• Drawing up and keeping up-to-date technical documentation.
• Making information available to AI system providers who integrate the model.
• Putting in place a policy to respect Union copyright law.
• Publishing a sufficiently detailed summary about the content used for training (as specified by the Act and related guidance).

Systemic-risk GPAI models — including those designated by the European Commission or meeting the Act’s compute-related criteria — face additional evaluation, risk mitigation, incident reporting and cybersecurity-oriented duties. Exact thresholds and designations evolve through implementing acts and Commission decisions; treat compute cut-offs as regulatory facts to verify, not marketing claims.

System transparency (Article 50)

Independently of whether a foundation model sits underneath, certain systems must:

• Inform people that they are interacting with an AI system (unless obvious).
• Mark synthetic audio, image, video or text content as artificially generated or manipulated in the cases the Act covers.
• Disclose emotion recognition or biometric categorisation systems to the people exposed, outside higher-risk regimes that may prohibit or further regulate those uses.

Deepfake-style content used in contexts such as informing the public on matters of public interest attracts specific labelling rules under the Act.

Practical documentation starters

1. Model card / system card — intended use, out-of-scope uses, evaluation summary, known limitations.
2. Integration note — which GPAI model versions power which systems.
3. Disclosure UX — where users see “you are chatting with AI” and how synthetic media is labelled.
4. Change log — model upgrades that may change behaviour or risk tier of the downstream system.

None of this replaces legal classification. It does give auditors a place to start.

V77 Trust includes model-card editing, vendor questionnaires for third-party model providers, and transparency-oriented control mappings so GPAI and Article 50 work does not live only in slideware.