c. General Purpose Artificial Intelligence Models: the Artificial Intelligence Act creates the classification of “general purpose artificial intelligence models” (GPAI Models) and implements rules that apply to the development and use of such models. According to article 3(63), by “general-purpose artificial intelligence model”, the Artificial Intelligence Act means an artificial intelligence model, including where such an artificial intelligence model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except artificial intelligence models that are used for research, development or prototyping activities before they are placed on the market. The Artificial Intelligence Act takes a risk-based approach: article 5 prohibits artificial intelligence systems with unacceptable risks, and in chapter 3, section 2, it imposes specific requirements on high-risk AI systems, while leaving artificial intelligence systems that pose low or minimal risks largely unregulated10. d. Transparency Obligations: The Artificial Intelligence Act also sets out transparency obligations for providers and deployers of certain artificial intelligence systems and applications. These obligations are applicable where artificial intelligence systems are used for specific, narrow functions, regardless of the context. It is important to note that this is not a fourth category of artificial intelligence systems but a list of obligations that apply to certain artificial intelligence systems and applications which pose specific risks whether they qualify as high-risk or not. Therefore, article 50 of the Artificial Intelligence Act establishes specific transparency obligations for the use of these systems, without prejudice to the requirements and obligations for high-risk artificial intelligence systems: 1. Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system. 2. Providers of AI systems, including general-purpose AI systems, generating synthetic audio, image, video or text content, shall ensure that the outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated. 10 Schuett, J. “Risk Management in the Artificial Intelligence Act”, European Journal of Risk Regulation (2024), 15, 367–385 90 PAULA CASADESUS RIPOLL
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