EU AI Act August 2 GPAI window 51 days out — US companies face transparency-disclosure obligations regardless of EU establishment
The August 2, 2026 EU AI Act compliance deadline for general-purpose AI (GPAI) systems is now 51 days away. Holland & Knight's June advisory confirms US companies face transparency disclosure obligations even without EU establishment — the regulatory reach attaches to the placing of AI systems on the EU market or affecting persons in the EU, not to the model provider's geography.
The substantive piece is the procurement-disclosure stack. GPAI providers must publish: a summary of training data (template provided by the AI Office), copyright-compliance documentation, model cards with capability and limitation disclosures, and downstream deployer disclosures. For OpenAI, Anthropic, Google, and Meta — all operating frontier GPAIs available in the EU — the August 2 deadline is the hard window. The political-agreement debate about delaying the deadline is now too late to bind effect; companies are deploying compliance documentation on the current schedule.
The Code of Practice on Content Marking and Labelling — published by the European Commission on June 10 — is the parallel obligation: deployer-side, attaching to who uses AI to generate content rather than who built the model. Combined, the two deadlines turn EU AI Act compliance from a model-weights disclosure question into a full content-supply-chain disclosure question.
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