The European Commission's enforcement powers under the EU AI Act took effect on August 2, 2025, ending the grace period for Chapter V. This chapter covers general-purpose AI models, and the Commission can now demand pre-release evaluations, restrict market access, and impose fines up to €15 million or 3% of global annual turnover, whichever is higher. The powers apply to any company offering a general-purpose AI model in the EU, regardless of where the company is headquartered. Non-EU providers must appoint an EU-based authorized representative.

Enforcement Powers and Penalties

The Commission can demand to evaluate models before they are released in the EU. If a company refuses to cooperate or provides misleading information, it can be fined on its own. Elisabetta Righini, partner at Sidley Austin, clarified: "Refusing an information request, giving misleading answers, or blocking a model evaluation is finable on its own." This means that even procedural violations carry significant financial risk.

Global Reach and Recent Actions

The EU's jurisdiction extends globally. As Righini noted, "A US address does not put a lab outside the EU regulator’s reach." The Commission is already in talks with OpenAI and Anthropic following recent cyber incidents involving their models, as reported by Reuters. The EU had sought access to Anthropic's Mythos model for months before the company agreed to share it in June. This indicates the Commission is actively engaging with major AI labs.

Transatlantic Tensions

This enforcement comes amid heightened transatlantic tensions. The Trump administration threatened the EU with "substantial" tariffs after Brussels fined Google $1 billion in July under the Digital Markets Act. Adding AI Act enforcement gives Brussels another lever against American tech companies. Anthropic's silence on open weights drew accusations that it wanted regulatory protection, and EU enforcement provides tools to demand model access that Anthropic was reluctant to give voluntarily.

Company Responses

OpenAI and Google have publicly stated their compliance intentions. Tom Gordon, VP of EMEA policy at OpenAI, said: "We’ve collaborated closely with the European Commission and the wider ecosystem on implementing the AI Act." Google said it remains "dedicated to meeting all applicable rules." However, the practical implications are significant for developers and companies using these models.

What This Means for Developers

If you're building on top of general-purpose AI models, this could affect your supply chain. The EU can now demand model evaluations before release, potentially delaying availability in the EU. If a provider like OpenAI or Anthropic refuses to comply, they could be fined or blocked, which could impact your access to their models. You'll need to monitor compliance announcements and plan for potential disruptions.

Practical Steps

  1. Review your AI providers' compliance status: Check if they have appointed an EU representative and are cooperating with the Commission.
  2. Assess your exposure: If your applications rely on models that might be restricted, consider fallback options.
  3. Stay informed: Follow the Commission's decisions and any enforcement actions that might affect model availability.

The Regulatory Landscape

The White House is also asserting control over who accesses frontier models. American AI labs now face two governments demanding pre-release review from opposite sides of the Atlantic, each with its own thresholds, timelines, and penalties. This dual oversight creates a complex compliance environment for AI companies.

The grace period is over. The EU has teeth, and it's already using them. If you're a developer or company using AI models, now is the time to assess your reliance on these providers and prepare for potential regulatory impacts.