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The EU published its first GPAI Code of Practice draft. You are probably not the addressee

Published 14 November 2024, it tells model providers how to meet obligations starting 2 August 2025. Useful to read anyway, for one reason.

On 14 November 2024 the EU AI Office published the first draft of the General-Purpose AI Code of Practice. It is the instrument that will show providers of general-purpose AI models how to comply with obligations that apply from 2 August 2025.

Four working groups are drafting it, covering transparency and copyright, risk identification, technical risk mitigation, and governance. It runs to dozens of pages and it will change before it is final.

Who this is actually for

Providers of general-purpose AI models. That means OpenAI, Google, Anthropic, Meta, Mistral and their peers — organisations that train and place such models on the EU market.

It is not for a Swiss engineering firm using a chatbot, a fiduciary using an AI bookkeeping feature, or a builder whose tender software has a summarise button. If you use a model rather than provide one, this document does not create obligations for you.

Read that sentence twice if a consultant has told you otherwise this month. A great deal of compliance selling is happening on the back of documents aimed at Silicon Valley.

Why read it anyway

One reason: it tells you what your suppliers are about to be required to publish.

The draft leans heavily on transparency — model documentation, summaries of training data, copyright policies. From August 2025 the providers behind your tools will have to produce this material for the EU market. It becomes public, or at least available downstream.

That is the first time a buyer will be able to ask « what is this model trained on and what are its known limitations? » and expect a documented answer rather than a shrug.

The practical step

Nothing to do now. One thing to diarise: when you next renew a contract that has an AI feature in it, ask the vendor whether the model provider behind it will publish documentation under the Code, and ask to be sent it when it exists.

Vendors who have thought about this will answer immediately. Vendors who have not will discover in mid-2025 that their own supplier chain needs work, and you will be glad you asked early.

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