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 5 prohibitions (unacceptable risk) in_force
• 2025-02-02 Article 4 AI literacy in_force
• 2025-08-02 GPAI model obligations (Articles 51 to 56) in_force
• 2026-07-27 Regulation (EU) 2026/1744 (Digital Omnibus on AI) enters into force — AI Act applies as amended in_force
• 2026-08-02 AI Act general date of application (Art 113) — governance, penalties and remaining provisions without a different date in_force
• 2026-08-02 Article 50 transparency obligations (AI-interaction disclosure, labelling of deepfakes and AI-generated text, emotion-recognition notices) in_force
• 2026-12-02 Article 50(2) machine-readable marking of AI-generated content — transition for generative AI systems placed on the market before 2 August 2026 scheduled
• 2026-12-02 NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM scheduled
• 2027-08-02 National AI regulatory sandboxes: at least one operational per Member State (Art 57(1)) scheduled
• 2027-12-02 Annex III stand-alone high-risk obligations scheduled
• 2028-08-02 Annex I embedded (regulated-product) high-risk obligations scheduled

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