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US Companies Advised to Assess EU’s General Purpose AI Rules

American AI developers and deployers should determine whether they could be subject to the European Union’s general-purpose AI (GPAI) requirements under the AI Act, attorneys at Arnold & Porter said Monday.

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The GPAI requirements went into effect Aug. 2. The European Commission issued guidelines July 18.

Arnold & Porter noted that if a company modifies a GPAI model, it becomes a provider if the “modifications significantly affect the model’s generality, capabilities, or risk profile,” based on the guidelines. Companies outside the EU would need to appoint an authorized representative within the EU if they’re subject to the requirements, they added.

They noted, however, that the guidelines are not binding, and the European Union Court of Justice is the only body that can “interpret the AI Act authoritatively.”