Only 8 models will face the EU's hardest AI rules—here's who made the list

The EU AI Act is coming, and while the regulation sounds sprawling and terrifying, the reality for most open source developers is far less dramatic. If you’re building on Hugging Face, the paperwork is manageable—and for the vast majority, it boils down to what you should already be doing: writing good documentation and being transparent about your data.

Here’s the crucial number that cuts through the noise. According to a Stanford study cited by Hugging Face, only eight models from seven developers currently meet the default “systemic risk” threshold of being trained with more than 10^25 FLOPs. The list is a who’s-who of frontier labs: Gemini 1.0 Ultra, Llama 3.1-405B, GPT-4, Mistral Large, Nemotron-4 340B, MegaScale, Inflection-2, and Inflection-2.5. If you aren’t Google, Meta, OpenAI, Mistral, NVIDIA, ByteDance, or Inflection, you can probably exhale.

For everyone else building limited-risk systems—chatbots, text-to-image generators, and other tools that interact directly with people—the obligations are refreshingly practical. You need to label your AI’s output so users know they’re talking to a machine. That means watermarking and clear disclosure, something Hugging Face is baking directly into its ecosystem with Gradio watermarking tools and model cards. If you’re deploying a system, you also have to inform people when they’re interacting with AI. “The information above needs to be provided with clear language, at the latest at the time of the user’s first interaction,” the guide states.

The timeline gives developers breathing room. The AI Office’s codes of practice—currently being drafted with industry input—are expected by May 2025, and enforcement doesn’t kick in until August 2026. For non-systemic open source GPAI models, the requirements center on documentation and compliance with existing copyright and privacy rules. You don’t need a squad of lawyers. You need a solid dataset card and an opt-out mechanism. The regulation’s bite, for now, is reserved for a very small club.