EU AI Act Art. 52: notification of a GPAI model meeting the systemic-risk threshold

Notify the Commission without delay, and within two weeks, once a GPAI model meets the Art. 51(1)(a) condition or it becomes known that it will

By Jorge García Aibar Reviewed 2026-09-24

From clause to evidence Build the artefact, then file every output it produces as a record that names AIGE-OBL-EUAIA-ART52. Drawn from chapter 08.

Text alternative

Clause: EU AI Act, Art. 52.
Duty holder: GPAI provider.
Applies from: 2025-08-02, In force.
Artefact: Compute ledger per model….
Layers: Layer 02, Layer 05.
Evidence record: Classification decision record.
Record schemas: Classification decision record .
The same topic in 12 other frameworks; the crosswalk section below links each clause.

When this obligation applies The first date in the row's status, then each later step: filled once its date has passed, outlined while it is still ahead of the review date.

Data table: the dates

Dates of AIGE-OBL-EUAIA-ART52
Date	Step	Detail
2025-08-02	In force	Obligations from 2025-08-02; enforcement from 2026-08-02
2026-08-02	Later step	Commission enforcement powers apply
2027-08-02	Later step	GPAI models placed on the market before 2025-08-02 comply by this date (Art. 111(3))

Id

AIGE-OBL-EUAIA-ART52

Instrument

EU AI Act (post-Omnibus) law

Compared side by side

ISO 42001 vs EU AI Act · NIST AI RMF vs EU AI Act

Clause

Art. 52

Duty holder

GPAI provider

Authority

AI Office

Applies from

2025-08-02 In force · Obligations from 2025-08-02; enforcement from 2026-08-02

Later dates

2026-08-02 Commission enforcement powers apply
2027-08-02 GPAI models placed on the market before 2025-08-02 comply by this date (Art. 111(3))

System class

GPAI model with systemic risk

The artefact that evidences it

Compute ledger per model lineage with a planned-compute threshold alert; notification record filed within two weeks.

What this obligation connects to Solid edges are direct relations, dashed ones looser (a case that cites the same article, a framework whose clauses only touch the topic); patterns and controls take the colour of their stack layer. Select a node to open it; the lists below give every relation in full.

Data table: every relation

Relations of AIGE-OBL-EUAIA-ART52
Family	Item	Relation
Same crosswalk topic	AI Verify 9.12.1, 5.5.1	Core clause
Same crosswalk topic	China Algo. Rec. AlgoRec Art. 24	Core clause
Same crosswalk topic	China Deep Synthesis DeepSyn Art. 19	Core clause
Same crosswalk topic	China GenAI Measures GenAI Art. 17	Core clause
Same crosswalk topic	EU AI Act Art. 49, Art. 71, Art. 6, Art. 3(1)	Core clause
Same crosswalk topic	ISO 42001 A.4	Core clause
Same crosswalk topic	NIST AI RMF GOVERN 1.6, GOVERN 1.7	Core clause
Same crosswalk topic	UK ATRS ATRS Tier 1	Core clause
Same crosswalk topic	CSA AICM STA-08, IAM-03	Related clause
Same crosswalk topic	GAO AI Accountability 3.1	Related clause
Same crosswalk topic	Korea AI Act Art. 33	Related clause
Same crosswalk topic	TC260 Framework 3.0 TC260 App. 2 II.2, TC260 4.4.1	Related clause

Patterns that build it

No pattern in the catalogue names this clause on its "Maps to" line yet; the artefact above is the engineering answer.

The same topic in other frameworks

From the topic crosswalk: the clauses filed under the same topics as this one. Mappings are illustrative, not a claim of conformity.

Inventory and registration

EU AI Act Art. 49 Registration (core)
EU AI Act Art. 71 EU database for high-risk AI systems (core)
ISO 42001 A.4 Resources for AI systems (core)
NIST AI RMF GOVERN 1.6 GOVERN 1.6: Mechanisms are in place to inventory AI systems and are resourced according to organizational risk priorities (core)
China Algo. Rec. AlgoRec Art. 24 Algorithm filing (core)
China Deep Synthesis DeepSyn Art. 19 Filing for public-opinion services (core)
China GenAI Measures GenAI Art. 17 Algorithm filing (core)
UK ATRS ATRS Tier 1 Summary information (the published record) (core)
AI Verify 9.12.1 Accountability: inventory AI systems and their data, tooling, computing and human resources according to risk priorities (core)
EU AI Act Art. 6 Classification rules for high-risk AI systems
TC260 Framework 3.0 TC260 App. 2 II.2 Identity and access management
TC260 Framework 3.0 TC260 4.4.1 CII registration and filing
EU AI Act Art. 3(1) Definition of an AI system
NIST AI RMF GOVERN 1.7 GOVERN 1.7: Processes and procedures are in place for decommissioning and phasing out AI systems safely and in a manner that does not increase risks or decrease the organization's trustworthiness
CSA AICM STA-08 Supply Chain Inventory
CSA AICM IAM-03 Identity Inventory
Korea AI Act Art. 33 Confirmation of high-impact AI
GAO AI Accountability 3.1 Documentation: catalog model and non-model components, along with operating specifications and parameters
AI Verify 5.5.1 Security: identify, track and protect AI-related assets (models, data, prompts, logs, assessments)

Source

Chapter 08, section EU AI Act, post-Omnibus, checked against its sources on the review date above.

Machine-readable

This obligation: /api/v1/obligations/aige-obl-euaia-art52.json
The register: /api/v1/obligations.json · CSV
Schema and stability promise: open data and API

Cite this obligation

García Aibar, J. (2026). EU AI Act Art. 52: notification of a GPAI model meeting the systemic-risk threshold (AIGE-OBL-EUAIA-ART52). In AI Governance Engineering: The Thesis & Body of Knowledge (v0.5.0). https://doi.org/10.5281/zenodo.22956197. https://aigovernanceengineer.com/obligations/aige-obl-euaia-art52. CC BY 4.0

BibTeX

@misc{aige2026obligation,
  author       = {Jorge García Aibar},
  title        = {{EU AI Act Art. 52: notification of a GPAI model meeting the systemic-risk threshold (AIGE-OBL-EUAIA-ART52)}},
  howpublished = {In AI Governance Engineering: The Thesis \& Body of Knowledge},
  year         = {2026},
  version      = {0.5.0},
  doi          = {10.5281/zenodo.22956197},
  url          = {https://aigovernanceengineer.com/obligations/aige-obl-euaia-art52},
  note         = {Version 0.5.0}
}