General Purpose AI Obligations Under the EU AI Act

General-purpose AI (GPAI) has shifted from experimentation to core business infrastructure. SMEs now rely on GPAI for drafting, support automation, analytics, and product features. Under the EU AI Act, this adoption requires governance discipline because risk emerges from deployment context, not model popularity.

Where GPAI obligations become practical

GPAI-related responsibilities intensify when outputs influence people materially. Internal brainstorming is usually lower impact than customer decisions, hiring support, eligibility scoring, or safety-related guidance. Teams should classify GPAI use cases by impact and apply controls proportionately.

SME GPAI control baseline

1. Model/vendor inventory
   
   Track each GPAI dependency, version, and usage owner.

2. Approved-use policy
   
   Define allowed and prohibited usage patterns.

3. Data handling controls
   
   Restrict sensitive data exposure in prompts and context windows.

4. Human oversight in consequential use
   
   Require review/override for outputs affecting rights or access.

5. Transparency and user communication
   
   Label AI interaction/content where legally or operationally appropriate.

6. Monitoring and incident loop
   
   Capture failures, hallucination patterns, misuse, and corrective actions.

Why version drift matters

GPAI behavior can change with provider-side updates. A workflow that was low-risk in one model version may become unstable or overconfident after updates. Teams should trigger reassessment when model/version or integration context changes.

Governance architecture that scales

• monthly GPAI usage review,
• release gate for high-impact GPAI features,
• centralized evidence index (controls, incidents, approvals),
• role-based training for staff interacting with GPAI outputs.

Common failure patterns

1. No documented boundary between drafting and decision support.
2. No owner for GPAI risk in each workflow.
3. Prompt/data policy exists but is not enforced.
4. Incident learnings do not feed back into controls.

Final takeaway

GPAI can be a major productivity advantage for SMEs when managed with explicit boundaries, oversight, and evidence. The compliance objective is not to slow adoption — it is to keep adoption reliable, defensible, and rights-aware as use scales.