GPT-5.4 Pro EU AI Act Compliance Profile
OpenAI
Your risk depends on how you use GPT-5.4 Pro
| Usage Context | Risk Level | Obligations |
|---|---|---|
| Internal coding tool | MINIMAL | 3 obligations (~12h) |
| Customer support bot | LIMITED | 7 obligations (~32h) |
| HR screening / hiring | HIGH | 19 obligations (~120h) |
| Credit decisions | HIGH | 19 obligations (~120h) |
| Medical triage | HIGH | 19 obligations (~120h) |
Why this tool is classified as GPAI
GPT-5.4 Pro is OpenAI's most advanced model, building on GPT-5.4's unified architecture with enhanced reasoning capabilities for complex, high-stakes tasks. It features a 1M+ token context window (922K input, 128K output) with support for text and image inputs. Optimized for step-by-step reasoning, instruction following, and accuracy, GPT-5.4 Pro excels at agentic coding, long-context workflows, and multi-step problem solving.
Applicable Articles
Who does what
OpenAI (provider)Their job
- Provider obligations being compiled
You (deployer)Your job
- •AI Literacy (Art. 4) (Art. 4)
- •AI Disclosure (Art. 50) (Art. 50)
- •Synthetic Content Labeling (Art. 50) (Art. 50)
Risk Assessment Reasoning
This model is classified as General-Purpose AI (GPAI) under the EU AI Act. GPAI providers must comply with transparency obligations (Art. 53), including technical documentation and copyright policy disclosure. Deployers must ensure AI literacy training (Art. 4) for all staff interacting with the system. Text generation models may produce synthetic content; deployers using this for public-facing applications must disclose AI-generated content (Art. 50).
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Frequently Asked Questions
What is GPT-5.4 Pro's EU AI Act risk classification?
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GPT-5.4 Pro is classified as GPAI under the EU AI Act. However, the risk level of your specific deployment depends on your use case: internal tools may be Minimal risk, while HR screening or credit decisions escalate to High Risk.
What are my obligations if I deploy GPT-5.4 Pro?
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As a GPT-5.4 Pro deployer, you have 3 base obligations (~16 hours estimated effort). Key articles: Art. 4, Art. 50.
What is GPT-5.4 Pro?
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GPT-5.4 Pro is a Text Generation model. It has 0 downloads on HuggingFace.
What are the EU AI Act deadlines for GPT-5.4 Pro?
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Already passed: AI Literacy (Art. 4) — 2025-02-02. Already passed: AI Disclosure (Art. 50) — 2025-08-02. Already passed: Synthetic Content Labeling (Art. 50) — 2025-08-02.
Check GPT-5.4 Pro compliance in your codebase
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