GPAI Technical Documentation Management

Prepare and maintain the technical documentation required for GPAI models and make it retrievable for regulators.

For a GPAI provider within Article 53(1)(a), maintain a versioned technical file covering the applicable Annex XI information. Record the model, development, training, testing and evaluation evidence with accountable owners, and update the file when relevant information changes. Prepare it for authorized regulatory requests and document alternative compliance evidence where required. Assess the qualifying free/open-source exception before relying on it; that exception does not cover systemic-risk models and does not remove the separate copyright or training-summary duties.

Prepare for the applicable model obligations; keep current after relevant changes; provide to authorities within applicable request deadlines.

Annex XI technical-file index and completeness review Versioned training, testing and evaluation records Model-change and approval records Documented exception analysis where relied on Regulator retrieval tests and alternative-compliance evidence

Select a model version and test retrieval of a required technical record. Check that the file reflects current training and evaluation information. Review the conditions supporting any free/open-source exception rather than relying on the licence label alone.