GPAI Code of Practice
GPAI governanceGeneral-Purpose AI Code of Practice (GPAI CoP) · European Commission / EU AI Office
The GPAI Code of Practice is the voluntary EU governance instrument through which GPAI model providers operationalize AI Act Articles 53–55 commitments. This AITBM-authored crosswalk offers an optional technical-risk measurement approach for relevant evidence artifacts; it neither signs the Code nor establishes or discharges any legal obligation.
| GPAI CoP Chapter | Primary AITBM Sub-Metrics | Evidence Use / Notes |
|---|---|---|
| Transparency - Documentation / Model Documentation Form | Tr-4Tr-1Tr-3 | ACI Pc; Tr axis + confidence; Art 53 |
| Copyright - copyright policy, TDM opt-out, lawful crawling | Pr-1Pr-3Tr-4 | ACI Pc; Pr axis; Art 53 (legal lawfulness not scored) |
| Safety & Security - model evaluations + adversarial testing | Ro-1Ro-4Ro-3 | ACI Ec + Tf reset on each re-run; Art 55 |
| Safety & Security - systemic-risk identification / analysis / acceptance | ORP Cp, Rf evidence | Scenarios and dependency records feed the SDG; Cp remains graph-derived; Art 55 |
| Safety & Security - safety mitigations (harmful output) | Cn-2Cn-3Fa-1Fa-4 | Cn / Fa axes; Art 55 |
| Safety & Security - security mitigations (model-weight cybersecurity) | Cn-4Cn-1Cn-5 | Cn axis; Art 55 |
| Safety & Security - serious-incident reporting + documentation | Tr-3Tr-4 | ACI Pc; confidence; Art 55 |
| Safety and Security Model Report | Tr-3Tr-4 | ACI Pc; consolidated evidence package; Art 55 |
Key findings
- The Code addresses provider commitments, while AITBM assesses technical risk, confidence, and evidence freshness. The Code does not prescribe one residual-risk score; this crosswalk offers AITBM as an optional measurement approach, not one specified or endorsed by the EU AI Office.
- Each commitment produces a concrete artifact (Model Documentation Form, copyright policy, evaluation/red-team reports, Safety and Security Model Report, incident logs) that an assessor consumes as objective evidence, reducing assessor discretion; recurring evaluations are the ideal ACI Tf refresh input.
- Boundary discipline: a favourable ERS does NOT demonstrate adherence, discharge any AI Act obligation, or carry standing before the AI Office; AITBM scores the evidence, not the signatory commitment - two signatories can have very different ERS profiles.
- The legacy worked example predates GDCP and the current ERS composition. A current assessment must rebuild the SDG, derive Aa/As/Cp/Rf, and use specification Section 5; systemic-risk designation alone does not set Cp.