Mark Booth, Steven Farmer, Scott Morton , JD Supra; EU AI Act at the Crossroads: GPAI Rules, AI Literacy Guidance and Potential Delays
"The EU AI Act (AI Act), effective since February 2025, introduces a risk-based regulatory framework for AI systems and a parallel regime for general-purpose AI (GPAI) models. It imposes obligations on various actors, including providers, deployers, importers and manufacturers, and requires that organizations ensure an appropriate level of AI literacy among staff. The AI Act also prohibits “unacceptable risk” AI use cases and imposes rigorous requirements on “high-risk” systems. For a comprehensive overview of the AI Act, see our earlier client alert.
As of mid-2025, the implementation landscape is evolving. This update takes stock of where things stand, focusing on: (i) new guidance on the AI literacy obligations for providers and deployers; (ii) the status of the developing a General-Purpose AI Code of Practice and its implications; and (iii) the prospect of delayed enforcement of some of the AI Act’s key provisions."
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