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FR

AIS-104

Technical-standards language model (licensed to clients)

Limited risk (transparency)Provider8/61 obligations

Already applicable: art.4 AI literacy and the art.53-55 GPAI model obligations. Compliance is owed from placement, not from a future date. Transitional deadline for the art.111(4) marking transition: 2 December 2026, because this system predates the rules. That transition is lost if the system is substantially modified.

⚠ Problems to check before validating (0)

None. The register raises no warning on this row — which is not the same as a validated row: a human still signs it off.

How this was decided

  1. CMYes — An AI system, with an art.2 connecting factor to the EU, and no exemption claimed.[CJ, CK, CL]From your answers to: Q1.1 — Does the tool produce predictions, content, recommendations or decisions — rather than simply displaying, storing or computing data? ; Q1.2 — Does the tool produce those outputs by LEARNING from data, or by applying a model — rather than by running rules a person wrote? ; Q1.3 — Does the output INFLUENCE something — a physical environment, a workflow, a document, a decision — rather than just sitting there? ; Q1.4 — Does the tool work on its own to some degree, producing its output without a person specifying every step? ; Q2.1 — Where is the tool used, and where are the people or the outputs it affects? (tick all that apply) ; Q2.2 — Does the tool fall into any of these cases?
  2. FLimited risk (transparency) — Not high-risk, but art.50 transparency duties apply: people must be told they are dealing with AI, or that content was generated by it.[DO]From your answers to: Q8.2 — Does the tool generate or manipulate content — text, images, audio or video?

Obligations that apply (8 of 61; 53 ruled out)

art.4 applies to every provider and deployer of any AI system in scope, whatever its risk level, and — on the value-chain reading of recital 20 — to a provider of a general-purpose AI model: the people who operate and are affected by it must have a sufficient level of AI literacy. (A GPAI model is not literally an "AI system", so the strict text is arguable; the register takes the broad, fail-safe reading, and this note flags it as such.)

  • art.4AI literacy (art.4)

The system generates or manipulates synthetic content beyond assistive standard editing. art.50(2) requires the output to be marked machine-readably as artificially generated.

  • art.50(2)Mark synthetic content machine-readable (art.50(2))

At least one art.50 transparency duty applies. art.50(5) governs HOW it must be discharged: clearly and distinguishably, at the latest at the first interaction or exposure, and accessibly.

  • art.50(5)Provide the information clearly and distinguishably at the latest at first interaction or exposure, meeting accessibility requirements (art.50(5))

GPAI provider duties that survive the art.53(2) open-source carve-out. A model released under a free and open-source licence with its weights is relieved of these — unless it carries systemic risk, in which case they apply regardless.

  • art.53(1)(a)Technical documentation of the model (art.53(1)(a)) — exemptible under art.53(2)
  • art.53(1)(b)Information to downstream integrators (art.53(1)(b)) — exemptible under art.53(2)

You fine-tune, retrain, or develop and distribute a general-purpose AI model, which makes you its provider. Consuming a model through an API would not — modifying it does.

  • art.53(1)(c)Copyright compliance policy (art.53(1)(c))
  • art.53(1)(d)Public summary of training data (art.53(1)(d))
  • art.53(3)Cooperate with the Commission and national competent authorities (art.53(3))

Compliance dates

  • Art.4 AI literacy have applied since 2 February 2025. A system or model first placed on the market on or after that date must comply from placement — there is no separate future transition deadline.
  • Transitional deadline for the art.111(4) marking transition: 2 December 2026, because this system predates the rules. That transition is lost if the system is substantially modified.
  • The art.53-55 GPAI model obligations have applied since 2 August 2025. A system or model first placed on the market on or after that date must comply from placement — there is no separate future transition deadline.

Answers behind it

Q1 · What does THE COMPANY do with this tool?
THE COMPANY sells or licenses an AI system or component to a Client or partner, under THE COMPANY's name
Q2 · At go-live, whose name or trademark is on it?
—
[B] High-risk area — Annex III
No
Personal data present? (GDPR art.4)
No

One worked example under the register v11 rules. Fictional data; no account, nothing stored.