AI Act Article 51: Obligations, Deadlines & Penalties

All obligations under Article 51

Obligation 1

A general-purpose AI model shall be classified as a general-purpose AI model with systemic risk if it has high impact capabilities evaluated on the basis of appropriate technical tools and methodologies, including indicators and benchmarks. Regulation (EU) 2024/1689, Article 51, Article 51

Obligated entity

provider

Action required

classify

Deadline

—

Penalty

—

Obligation 2

A general-purpose AI model shall be classified as a general-purpose AI model with systemic risk if, based on a decision of the Commission, it has capabilities or an impact equivalent to those set out in point (a) having regard to the criteria set out in Annex XIII. Regulation (EU) 2024/1689, Article 51, Article 51

Obligated entity

provider

Action required

classify

Deadline

—

Penalty

—

Obligation 3

A general-purpose AI model shall be presumed to have high impact capabilities when the cumulative amount of computation used for its training measured in floating point operations is greater than 10^25. Regulation (EU) 2024/1689, Article 51, Article 51

Obligated entity

provider

Action required

presume

Deadline

—

Penalty

—

Obligation 4

The Commission shall adopt delegated acts to amend the thresholds listed in paragraphs 1 and 2 of this Article, as well as to supplement benchmarks and indicators in light of evolving technological developments. Regulation (EU) 2024/1689, Article 51, Article 51

Obligated entity

Commission

Action required

adopt

Deadline

—

Penalty

—

EU AI Act compliance deadlines

• 2025-02-02 Article 4 AI literacy in_force
• 2025-02-02 Article 5 prohibitions (unacceptable risk) in_force
• 2025-08-02 GPAI model obligations (Articles 51 to 56) in_force
• 2026-08-02 Article 50(2) machine-readable marking (watermarking) of AI-generated content provisionally_amended
• 2026-08-02 Article 50 transparency obligations OTHER than the 50(2) marking grace (for example disclosure that a user is interacting with an AI system) scheduled
• 2026-08-02 Annex III stand-alone high-risk obligations provisionally_amended
• 2026-08-02 National AI regulatory sandboxes (establishment deadline) provisionally_amended
• 2026-12-02 NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM provisionally_amended
• 2027-08-02 Annex I embedded (regulated-product) high-risk obligations provisionally_amended

Questions about Article 51

Who must comply with Article 51 of the AI Act? +

Commission, provider.

What does Article 51 of the AI Act require? +

classify presume adopt