Systemic Risk – Art. 55
Criterion
A GPAI model is classified as posing systemic risk if:
- The cumulative computing power for training exceeds 10²⁵ FLOPS (Annex XIII), OR
- The EU Commission classifies it by decision
Providers must notify the Commission within 2 weeks when their model meets this criterion.
Affected Models (as of March 2026)
Models that, based on current knowledge, are or may be considered as posing systemic risk:
- GPT-4/4o (OpenAI)
- Claude 3.5/4 (Anthropic)
- Gemini Ultra/Pro (Google)
- Llama 3.1 405B (Meta)
BAUER GROUP Relevance
None directly. The BAUER GROUP is a user of these models, not a provider. The obligations under Art. 55 apply to the respective model providers.
Indirect relevance: The BAUER GROUP should verify, as part of its vendor selection (vendor due diligence), whether the GPAI provider fulfils its obligations. This reduces its own liability risk when integrating into customer products.