AI Act & GPAI

General-Purpose AI Compliance: Provider and Deployer Responsibilities

By Jonas Osman Abdelghafour · 26 September 2026

Independent analysis by Jonas Mohamed Osman Abdelghafour, known as Yonas Osman, CEO of Quantica Risk Modelling. Educational information only; legal obligations depend on role, system and jurisdiction.

General-purpose AI creates a responsibility question that is easy to overlook in procurement: is the organisation developing, adapting, integrating or deploying the system, and which duties belong to each role? A financial institution should document that boundary before a model is embedded in a customer or risk process.

Map the AI supply chain

Record the foundation model, fine-tuning provider, retrieval layer, application owner, cloud host and business user. Identify who controls training information, updates, safeguards, logs and incident communication. A contract with an application vendor may still leave the institution responsible for how the system is used.

Control downstream adaptation

Fine-tuning, tool access, retrieval data and prompts can change the system's risk profile. Require a new assessment when the purpose, data, output or customer impact changes. Do not assume that a vendor's general assurance report covers the institution's configuration.

Make role evidence auditable

Keep a responsibility matrix, technical documentation, approved purpose, model version, monitoring results and incident route. The Commission's GPAI guidance and AI Act text provide the legal reference points.

About the author

Jonas (Yonas) Osman Abdelghafour writes about financial risk management, quantitative modelling, actuarial science, banking risk, insurance risk, capital modelling, model validation, climate risk and geopolitical risk. His work focuses on translating complex quantitative and regulatory risk issues into practical frameworks for financial institutions. Author profile.