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Downstream modifier (GPAI)

By Updated

An actor that fine-tunes or modifies another provider's general-purpose AI model. The Commission's guidelines make it the modified model's provider only when the modification uses over a third of the original training compute; its Art. 53(1) duties then cover the modification, but a modified systemic-risk model is presumed to keep that risk and its duties 12.

Developed in
ch. 15, When a deployer becomes a provider
ch. 18, When a fine-tuner becomes a GPAI provider
Chapters
ch. 15, Deployment · ch. 18, EU AI Act
Contrast with
Downstream provider
Source
2 numbered references, listed below

Where it is used

2 chapters of the Body of Knowledge use the term. Each link opens the first section that does.

  • Fine-tuning

    Further training of an existing model on new data to adapt it to a task or domain.

  • Substantial modification

    Under the EU AI Act, a change after placing on the market that the initial conformity assessment did not foresee and that affects compliance or changes the…

  • GPAI

    General-purpose AI model: under the AI Act, a model that shows significant generality, can competently perform a wide range of distinct tasks and can be…

  • Provider

    Under the EU AI Act, whoever develops an AI system or general-purpose AI model, or has one developed, and places it on the market or puts it into service…

Sources

  1. [1] Guidelines on obligations for general-purpose AI providers, FAQ (a modifier becomes a provider only when the modification uses more than one third of the original model's training compute; obligations limited to the modification). European Commission. 2025. https://digital-strategy.ec.europa.eu/en/faqs/guidelines-obligations-general-purpose-ai-providers (verified: primary)
  2. [2] Commission Guidelines on the scope of the obligations for providers of general-purpose AI models (content approved 18 July 2025 by C(2025) 5045 final; formal text C(2025) 7719 final of 19 Nov 2025; paras. 65 to 68 on modifiers; non-binding; indicative criterion of training compute above 10^23 FLOP with the ability to generate language, images or video). European Commission. 2025-11-19. https://digital-strategy.ec.europa.eu/en/library/guidelines-scope-obligations-providers-general-purpose-ai-models-under-ai-act (verified: primary)

Definitions of legal terms paraphrase the cited text, which governs. Dated statements are as of .

Cite this term

García Aibar, J. (2026). Downstream modifier (GPAI). In AI Governance Engineering: The Thesis & Body of Knowledge (v0.5.0), Glossary. https://doi.org/10.5281/zenodo.22956197. https://aigovernanceengineer.com/glossary/downstream-modifier-gpai. CC BY 4.0

BibTeX

@misc{aige2026downstreammodifiergpai,
  author  = {Jorge García Aibar},
  title   = {{Downstream modifier (GPAI)}},
  note    = {Glossary, AI Governance Engineering: The Thesis \& Body of Knowledge, version 0.5.0},
  year    = {2026},
  doi     = {10.5281/zenodo.22956197},
  url     = {https://aigovernanceengineer.com/glossary/downstream-modifier-gpai}
}