Your GPAI Compliance Strategy Has a Vendor-Shaped Hole

The EU AI Act's General Purpose AI (GPAI) requirements are creating compliance obligations that most organizations haven't fully mapped to their vendor relationships. While we've covered the broader implications of these regulations elsewhere, there's one critical operational reality that deserves immediate attention: under the Act, your vendors' compliance gaps become your liability.

Organizations are discovering in real-time that their "enterprise-ready" AI vendors can't answer basic questions about data lineage, training data documentation, or incident response timelines. These gaps create regulatory exposure that is leaving your organization at risk.

The solution requires a systematic vendor assessment: specific questions you need to ask every AI vendor in your stack, from model providers to data processing services to pipeline components. So, we've developed a comprehensive list.

In this article, we'll walk through the most important vendor conversations and what their responses reveal about compliance readiness. For the complete assessment toolkit, including all 37 specific questions, detailed scoring methodologies, follow-up frameworks, and response templates you can use immediately—download our full GPAI Vendor Compliance Questionnaire.

Using This Assessment Framework

These questions form the core of a systematic vendor evaluation process. You can use them to send them to every vendor providing AI models, data processing, or pipeline components in your stack. Score their responses using clear criteria: vendors with acceptable answers across critical areas represent manageable risk; those with multiple gaps or unwillingness to address issues require alternative evaluation.

The assessment process itself reveals vendor maturity and commitment. Don't be surprised if some vendors find these questions challenging—many haven't fully considered GPAI regulatory implications. Better to identify these gaps during procurement than discover them during regulatory review.

The August 2027 compliance deadline provides planning time, but vendor assessment and remediation need to begin now. Vendors require development time for missing capabilities, contracts need renegotiation to address compliance responsibilities, and alternative vendor evaluation takes time when primary vendors cannot meet requirements.

These questions provide the information necessary to make informed decisions about which vendor relationships support long-term compliance success and which create ongoing regulatory exposure.

Basic GPAI Awareness

Start every vendor assessment with this fundamental question: "Are you aware of the EU AI Act's requirements for General-Purpose AI models?"

Most vendors will tell you they're "aware" of GPAI requirements, but their follow-up responses reveal everything. If they've already built a compliance program, you're in good shape. If they're "still assessing requirements," they're behind but might catch up with enough lead time. But if they respond with "no" or "not sure"? Stop the conversation there: this vendor isn't ready for what's coming.

Follow up immediately with: "Do you have documented policies for GPAI compliance?" Too many vendors respond with "in development" without target dates. These are vendors hoping compliance requirements will somehow clarify themselves over time while they focus on other priorities.

Then ask the question that reveals their true commitment: "Will you provide contractual guarantees for GPAI compliance support?" Vendors who respond "negotiable" or "no" are telling you they won't accept responsibility for compliance gaps their services create. If they won't put compliance support in writing, they're transferring all regulatory risk to your organization.

Data Lineage

GPAI compliance demands detailed documentation of how data flows through AI systems, specifically, column-level tracking of transformations and dependencies. This is where you'll discover the biggest gaps in vendor relationships by asking the right questions.

Start with: "Can you provide complete data lineage for your services?"

The responses expose everything about vendor preparation. Some can provide column-level lineage that shows exactly which fields get processed and how they're transformed. Others offer only "high-level documentation" or admit they have "no lineage available." The difference matters because GPAI compliance isn't satisfied by knowing data flows from System A to System B—you need to document which specific fields are processed, how they're transformed, and what business logic governs those transformations.

Next, ask about operational accessibility: "Can you provide real-time or API access to lineage information?" Vendors who can only provide lineage through "manual requests" create bottlenecks that make ongoing compliance impossible. When you're managing multiple AI systems across different vendors, you can't rely on manual processes that don't scale.

Consider what this means in practice. Let's say your AI vendor processes customer sentiment analysis. When you ask these lineage questions, can they tell you which specific customer record fields influence sentiment scoring? Can they document how customer interaction history gets weighted in the analysis? Most vendors can describe their general process, but few can provide the field-level detail that compliance auditing requires.

Training Data Documentation

Model providers face some of the most complex GPAI requirements around training data documentation. The regulations require detailed information about data sources, processing methods, and copyright compliance.

Ask directly: "Can you provide complete documentation of training data sources?" Many respond "No, it's proprietary." But here's the thing: proprietary concerns don't exempt you from regulatory requirements. They just indicate the vendor hasn't figured out how to manage intellectual property alongside compliance obligations.

Follow up with: "Can you prove absence of copyrighted material in training data?" Some vendors can provide audit trails proving copyright compliance in their training processes. Others rely on "best effort" filtering or admit they "cannot guarantee" copyright compliance. The "cannot guarantee" response should concern you—it means potential copyright violations for you.

Don't forget to ask: "Do you maintain training data artifacts, and for how long?" Many vendors delete training data after model completion to reduce storage costs and limit breach exposure. But GPAI compliance may require reconstructing training processes years after initial development. Vendors with limited retention periods cannot support the long-term auditability that compliance frameworks anticipate.

Monitoring and Incident Response

GPAI compliance requires real-time visibility into AI system operations and structured incident response capabilities that go far beyond standard system monitoring.

Start with the basics: "What operational metrics do you expose?" Vendors who cannot provide audit logs represent immediate compliance risks because they can't support the detailed incident reconstruction that regulatory reviews require.

Then get specific about timelines: "How quickly can you provide audit logs for compliance reviews?" Responses like "within 1 week" or "no formal SLA" indicate vendors who haven't considered the rapid response that AI compliance demands. The EU AI Act's emphasis on transparency suggests organizations may need to report significant AI incidents within 72 hours, which requires vendor notification and preliminary analysis within much shorter timeframes.

Ask about incident response content: "What information is included in incident reports?" You need root cause analysis, affected systems identification, timeline documentation, and detailed remediation steps. Vendors who provide "ad-hoc" incident reporting can't support the audit trail documentation that regulatory reviews require.

Human Oversight Requirements

For high-risk AI applications, GPAI compliance mandates meaningful human oversight capabilities—systems that can review and override AI decisions when necessary, not just generate reports for later review. This creates technical integration requirements that many vendors haven't considered in their platform design.

Ask: "Do you support human review workflows?" The requirement isn't satisfied by just monitoring AI outputs after decisions are made. You need systems that can pause automated decision-making, route decisions through human reviewers, and maintain complete audit trails of interventions.

Follow up with: "Can humans override AI decisions in your system?" Some vendors provide comprehensive override systems that log who made decisions, what information they considered, and how overrides affected downstream processes. Others treat human oversight as an optional feature or assume customers will build their own oversight mechanisms using basic API access.

Finally: "Do you maintain audit trails for human interventions?" When humans override AI decisions, those actions must be logged with sufficient detail to support compliance auditing years later. This means documenting not just what decisions were overridden, but what information was available to human reviewers and what criteria they used to evaluate AI recommendations.

Reading Vendor Responses

Immediate red flags should pause procurement discussions. No GPAI awareness means the vendor can't provide meaningful compliance support regardless of their technical capabilities. No audit log capabilities means they can't support ongoing compliance verification. Using "proprietary" as a blanket excuse for providing no documentation indicates they haven't thought through how to balance IP protection with regulatory requirements.

Yellow flags suggest vendors who understand requirements but need development time. Manual-only processes indicate awareness without automation. "In development" responses without specific dates suggest vendors who recognize requirements but haven't prioritized implementation. Limited retention periods and no API access create operational challenges but might be addressable through contract negotiations.

Green flags indicate vendors building for long-term compliance partnership. ISO 42001 certification demonstrates investment in AI management standards that align with GPAI requirements. Real-time lineage APIs show understanding of ongoing compliance operational needs. Automated bias testing indicates they're considering fairness requirements beyond basic functionality. Contractual compliance guarantees with liability acceptance show vendors willing to align their incentives with your compliance needs.

When Initial Responses Fall Short

When vendors provide problematic initial responses, specific follow-up questions reveal whether gaps represent temporary limitations or fundamental compliance challenges.

When vendors claim proprietary constraints, ask them to provide redacted documentation that shows process and structure without revealing proprietary details. Vendors committed to compliance will find ways to provide necessary information while protecting intellectual property. Those using proprietary concerns as blanket excuses are revealing their priorities.

When vendors claim "customer responsibility" for compliance activities, ask for a detailed breakdown showing exactly which compliance activities are vendor responsibility versus customer responsibility. This forces vendors to be specific about what they will and won't support, rather than using vague language that transfers undefined risk.

When vendors lack documentation entirely, ask what it would take to create the documentation and whether you can fund development as part of your contract. Some vendors genuinely want to support compliance but need resource allocation to develop capabilities. Others will reveal through their responses that compliance isn't a strategic priority.

Moving Forward

No vendor relationship is irreplaceable, but GPAI compliance requirements are definitive. Systematic vendor assessment provides the information necessary to make informed decisions about which relationships support long-term compliance success and which create ongoing regulatory exposure.

Ready to comprehensively evaluate your vendor stack's GPAI readiness? Download our complete GPAI Vendor Compliance Questionnaire—a detailed 12-section assessment covering everything from basic awareness through contractual commitments, with scoring methodologies and response templates that identify compliance gaps before they impact your regulatory strategy.