CLAIM-2026-08-15-04

The Commission's Guidelines on the scope of obligations for providers of general-purpose AI models, adopted 18 July 2025, give as an indicative criterion that a downstream modifier is considered the provider of a general-purpose AI model where the training compute used for the modification is greater than a third of the training compute of the original model.

Why it matters

This is the line at which a deployer stops being a deployer. Teams treat fine-tuning as a product decision; the Commission treats a large enough one as a change of legal role.

Sources

• europeancom2026generalpu
• freshfields2025eu
• wilmerhale2025european