Providers of general-purpose AI models placed on the market before 2 August 2025 must take the necessary steps to comply with the obligations in the Regulation by 2 August 2027, under Article 111(3). The transition gives time to build the Article 53 and, where relevant, Article 55 file for an existing model, but it does not remove the duties and it does not extend to models placed on the market on or after 2 August 2025.
What does Article 111(3) actually say?
Article 111(3) provides, in outline, that providers of general-purpose AI models placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in the Regulation by 2 August 2027. The wording is a duty to take necessary steps by a date, not a statement that the obligations do not apply until that date and not a permission to do nothing in the meantime. A provider relying on the transition should therefore have a dated plan that shows the steps, the owners, and the timetable for reaching compliance by 2 August 2027. The plan should be linked to the model version and to the placing date relied on, so that a supervisor can see both the basis for the transition and the progress toward compliance. An undated assertion that a model is transitional, without a plan, is not a useful record.
How is the placing date established?
The placing date is the date the model was placed on the market, as defined in the Act. For a hosted model, a downloadable model, and a model integrated into another product, the relevant act and date can differ, and the evidence will differ too. A provider should record, for each model version, the placing act, the date, the geography, and the evidence relied on, such as release records, distribution logs, or first availability records. Where a model was made available in stages, or where an earlier version was replaced, the provider should record which version the transition is claimed for and whether a later version amounts to a new placing. If the placing date is uncertain, the uncertainty should be recorded and referred for qualified review, rather than resolved by choosing the most favourable date without evidence.
For the broader regulatory framework, see General-purpose AI models overview.
What work should be done during the transition?
During the transition, a provider should build the Article 53 file for the model, including technical documentation, downstream information, copyright policy and training summary, and, where the model presents systemic risk, the Article 55 file as well. That work can be substantial for an older model, particularly where training content information is incomplete or where evaluation evidence was not kept in a form that matches the current requirements. The provider should prioritise the gaps that affect downstream providers and supervisors first, record what cannot be reconstructed and why, and disclose and justify those cases in the relevant documents where the Act and guidance call for it. A provider should not assume that retraining or unlearning is required where it is not possible or would impose a disproportionate burden; the position should be assessed, documented and justified on the facts.
What happens to a model that is updated during the transition?
An update during the transition can change the analysis. A minor update that does not amount to a new placing may leave the transition intact for the original model, while a substantial change, a retraining run that creates a new model, or a new placing of a new version may need to be treated as a new model for Chapter V purposes. The provider should record each update, assess whether it creates a new placing, and update the documentation and downstream pack accordingly. The version history should show the original placing date, each update, and the compliance position for each version. A provider that treats every update as covered by the original transition, without assessing the update, risks applying the wrong date to a new model. Conversely, treating every patch as a new placing can create unnecessary churn; the assessment should be reasoned and recorded.
How should downstream providers be told?
Downstream providers integrating a transitional model need to know the model's transition status, the timetable for the Article 53 pack, and any gap in the information available to them. The model provider should communicate the status in the downstream pack or in a covering note, with the placing date relied on, the 2 August 2027 date, and the plan for closing gaps. Downstream providers should record what they were told, what they still need, and how the gap affects their own system assessment. A downstream provider should not treat a transitional model as if its Chapter V file were complete, and should not delay its own system work until 2027 where system duties already apply. The communication should be dated and versioned, so that both sides can show what was known and when.
Continue with Chapter V map for general-purpose AI models.
What does this guide not decide?
This guide does not decide whether a particular model was placed on the market before 2 August 2025, whether an update amounts to a new placing, or whether a provider has taken the necessary steps to comply by 2 August 2027. It does not assess a training content gap, a copyright policy, or a downstream pack. Those questions depend on release evidence, version history, the actual documents, and the consolidated legal text, including Article 111 as amended. A provider should confirm its transition position with a competent authority or legal adviser, keep a dated compliance plan, and revisit the position whenever the model is updated or new guidance is published.
Frequently asked questions
Does the transition mean no duties apply until 2027?
No. Article 111(3) requires providers of models placed on the market before 2 August 2025 to take the necessary steps to comply by 2 August 2027. The provider should have a dated plan and should build the Article 53 and, where relevant, Article 55 file during the transition, rather than waiting until the deadline.
What if a model was placed on the market after 2 August 2025?
The Article 111(3) transition does not apply to that model. Chapter V duties apply from 2 August 2025 for models placed on the market on or after that date, and the provider should meet the Article 53 and, where relevant, Article 55 duties for that model without relying on the transitional date.
How should an update be treated?
Record the update, assess whether it amounts to a new placing or a new model version, and update the documentation and downstream pack accordingly. The version history should show the original placing date, each update, and the compliance position for each version, with the reasoning recorded.
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This article is an informational overview, not a legal determination. Check the current legal text and official implementation guidance for your system and role.
Consolidated Regulation (EU) 2024/1689 ↗AI Act Service Desk Article 111 ↗Commission AI Act Service Desk timeline ↗