European regulators finalized the next enforcement phase of the AI Act, sharpening transparency and disclosure duties for general-purpose models and downstream deployers shipping into the EU.
Timeline
Builders must document training-data summaries, publish systemic-risk mitigations where applicable, and provide contact points for downstream integrators. Smaller open-weight releases face lighter templates but not a full exemption.
The rules land on a staggered calendar: largest frontier providers first, then mid-tier model makers, then deployers embedding models in customer-facing products.
Legal teams advise treating disclosure packs as living documents — updated with each major fine-tune or capability unlock, not a one-time PDF at launch.
Disclosure packs should update with every major fine-tune — not a one-time launch PDF.
