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Obligations for general-purpose AI providers

If you train and release a general-purpose model — including fine-tunes that go far enough to make you a provider — a separate set of duties applies, and the threshold question of whether your model carries systemic risk changes the answer substantially.
Obligations for general-purpose AI providers
If you train and release a general-purpose model — including fine-tunes that go far enough to make you a provider — a separate set of duties applies, and the threshold question of whether your model carries systemic risk changes the answer substantially.
For model providers, not model users
Contact us

What we work through

Starting with the question that determines everything else: are you a provider at all?
01

Are you a provider

Fine-tuning, distillation and substantial modification can move the duties onto you. This is decided on facts, not on labels.
02

Systemic risk

Whether your model meets the threshold, what follows if it does, and what evidence supports either answer.
03

Technical documentation

Model documentation and the information downstream providers need to meet their own obligations.
04

Copyright and training data

A policy for respecting rights reservations, and the public summary of training content.

What is included

01

Provider determination

Written, with reasoning — the question that everything downstream depends on.
02

Documentation set

Prepared to the structure expected of GPAI providers.
03

Copyright policy

Practical, and matched to how your data pipeline actually works.
04

Reviewed by a lawyer

Signed off, not inferred.

Common questions

How does work start?

With a diagnosis, not a proposal. The first week is spent understanding where you actually are — what is built, what is signed, what is exposed. Only then does the scope get fixed, because a scope written before that is a guess.

How is it priced?

Fixed scope, fixed price, agreed before work starts. We do not bill by the hour: it makes the client pay for our learning curve and rewards slowness. If a question turns out to be bigger than the scope, we say so rather than quietly extending the invoice.

Can we just talk first?

Yes. A one-hour consultation costs $299 and is paid in advance; you pick the time from real availability after payment. You get a written summary with the recommendations afterwards, and if an hour turns out to be the wrong format we say so before you pay.

Which countries do you work with?

The EU, the US and MENA, remotely, with local partners where a filing has to be made by someone admitted in that jurisdiction. We tell you up front when something needs a local lawyer rather than us.

Who actually does the work?

The people you speak to. There is no layer of juniors between the first call and the delivery — which is also why the scope is fixed rather than open-ended.

BOOK A CALL

Talk it through

One hour, fixed price, paid up front. You pick the time after payment — the calendar shows real availability, so the slot you take is the slot you get.

One-hour consultation

$299
  • ✓60 minutes, video call
  • ✓You pick the time after payment — the calendar shows real availability
  • ✓Written summary with the recommendations afterwards