Second GPAI draft published, six weeks to the first deadline
The EU AI Office issued a second draft on 19 December 2024. For an SME the relevant date is still 2 February, and the work is still one page.
On 19 December 2024 the EU AI Office published the second draft of the General-Purpose AI Code of Practice, with more detail than November’s first version, more concrete examples, and more attention to proportionality. Further drafting rounds are planned into 2025.
As in November, this document addresses model providers. If you use AI rather than build it, it creates no obligation for you. What it does confirm is that the transparency material your suppliers will have to produce is becoming real.
The date that does apply to you
2 February 2025 — six weeks from today. Two things start: the prohibited practices, and the AI literacy obligation.
For almost every Swiss SME the prohibitions are irrelevant in practice, with the one exception worth re-checking: emotion inference in the workplace. Some HR analytics, call-centre sentiment scoring and productivity monitoring products fall inside that ban. If you bought something in that family, read the ban text once.
The literacy obligation is the one that applies broadly, and it is satisfied by evidence that the people using AI systems understand them well enough for their role.
The one page that discharges it
Not a policy framework. One page, dated, covering five things:
- Which AI tools we use, and for what.
- What may be entered and what may not, in concrete terms.
- That outputs are checked by a person before they are used or sent.
- Who to ask when something is unclear.
- Confirmation that staff who use these tools have read it.
That last line is the evidence. Everything else is the content.
The Swiss caveat
Switzerland is outside the EU, so the Act reaches you only through its extraterritorial scope — placing an AI system on the EU market, or your system’s output being used there. Many SMEs are genuinely outside.
Write down that conclusion with the date and the reasoning. An unwritten « we checked and it does not apply » is worth nothing in eighteen months when somebody asks. The same page that handles literacy can carry that sentence, and then the whole matter is closed until you change something.