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GPAI obligations enforceable from 2 August 2026 - not postponed

GPAI Governance Check

You use GPT, Claude, Gemini or other general-purpose AI? In 1 day you'll know which GPAI obligations of the EU AI Act apply to your business - and whether fine-tuning or embedding has already put you in the provider role. Remote, fixed price.

2,500 EUR fixed price · Bookable within 1–2 weeks

The only AI Act deadline still live in 2026

The Digital Omnibus postponed the high-risk obligations to December 2027 - but not the GPAI obligations. They have applied since August 2025 and become enforceable with fines from 2 August 2026.

A provider without knowing it

Fine-tuning a GPAI model, offering it under your own brand, or embedding it in products can put you in the provider role - with documentation, transparency and copyright obligations.

Shadow AI in business units

GPAI is built into more and more SaaS tools - often without central review. No inventory means no role clarity, and no role clarity means no compliance.

Fines up to 15M EUR

Or 3% of global annual revenue - enforceable from 2 August 2026, flanked nationally by the German implementation act.

Labelling on top

Since August 2026, the transparency obligations (Art. 50) also apply: chatbots and AI-generated content must be recognisable as such.

How the GPAI Check works

1 day, 3 blocks, fully remote.

Workshop: GPAI inventory

3 hours · Morning

Joint rapid assessment with IT and business units: which GPAI models and services are in use - purchased, embedded, fine-tuned? The top 10 systems including shadow AI.

Analysis: roles + obligations

2 hours · Afternoon

Simon Schilling classifies each system's role (deployer or provider - with reasoning) and maps the GPAI obligations: technical documentation, transparency, copyright policy, training data summary, labelling.

Results call

1 hour · Afternoon

Obligations traffic light, critical systems, clear prioritisation: what must be in place before enforcement starts, and what can wait until the high-risk deadline in December 2027?

What you get

GPAI inventory (top 10)

All relevant GPAI models and services in your company - including the tools that were never centrally reviewed.

Role classification with reasoning

Per system: deployer or provider? The answer determines your scope of obligations - documented and defensible.

Obligations traffic light + executive summary (5 slides)

Red/yellow/green per system against GPAI and labelling obligations, with a prioritised action recommendation - ready for your leadership team.

1 day
Delivery (remote)
2,500 €
Fixed price, plus VAT
Top 10
GPAI systems assessed

Which entry point fits you?

The AI Act Quick-Check answers the broad question: does the AI Act affect us, where do we stand overall? The GPAI Governance Check goes deep along the only deadline still live in 2026: what do the GPAI obligations mean for us specifically? Same format, same price - you start with the check that fits your situation, not with both.

Staged model: check results flow seamlessly into the AI Act Readiness Assessment — no duplicated effort. For ongoing governance there is the Fractional AI Officer.

1 day of clarity on your GPAI obligations. 2,500 EUR fixed price.

Write to me — I'll get back to you within 24 hours with a scheduling proposal.

Book GPAI Check

30 Min · Video-Call · unverbindlich