CLAIM-2026-08-15-06

Where a downstream modifier becomes the provider of a general-purpose AI model without systemic risk, its obligations are limited to the modification conducted — documenting the changes made and the new training data — rather than the model as a whole.

Why it matters

It bounds the exposure. Crossing the line does not mean documenting somebody else's model — it means documenting your own delta, which is a tractable engineering artefact if it is recorded as you go.

Sources

• europeancom2026generalpu
• freshfields2025eu