← Practitioner
Module 7 of 10 · 15 min
Stage 2 · Apply the rules to real scenarios

GPAI provider vs downstream responsibilities

Map upstream and downstream responsibilities around general-purpose models.

Learn

A GPAI model provider has model-level duties; a downstream company may be a provider or deployer of a separate AI system built on that model.

Gather upstream documentation on capabilities, limitations and relevant model information needed by the downstream organisation.

If the client substantially changes or re-releases a model, reassess its role rather than assuming it remains a simple user.

Remember
  • •Separate model and system.
  • •Map the supply chain.
  • •Demand the information needed downstream.
Client practice

Draw the responsibility chain for a client that uses a GPAI API to build a branded customer-risk product.

Evidence you should be able to produce
Supply-chain mapModel evidence listClient role rationale
Source basis

Based on the uploaded EU AI Specialist lesson notes and checked against the consolidated EU AI Act in force on 27 July 2026. Where the source pack and current law differ, the current law wins.

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