Facility Threshold Atlas

The provider files first, and privately. Once a model meets the Article 51(1), point (a) condition, or it becomes known that it will, the provider “shall notify the Commission without delay and in any event within two weeks”; the presumption that pulls a model into that condition is Article 51(2), the 10²⁵ FLOP line. Notifications travel through the Commission's EU SEND platform (“EU SEND ensures the confidentiality, integrity, and authenticity of the information shared”) or the AI Office's dedicated mailbox, under Article 78 confidentiality. The public's side of the bargain is Article 52(6): “The Commission shall ensure that a list of general-purpose AI models with systemic risk is published and shall keep that list up to date, without prejudice to the need to observe and protect intellectual property rights and confidential business information or trade secrets in accordance with Union and national law.” Provider-side privacy is the Act's design; the register is the single public surfacing the Act provides.

That register has not appeared. Chapter V has applied since 2 August 2025 (Article 113); the publication duty carries no internal deadline, and ten months on, none of the eleven Commission surfaces enumerated in the log below carries the list or a link to it. Everything around it shipped on time. The GPAI Guidelines landed on 18 July 2025, the Code of Practice on 10 July 2025, the training-content summary template on 24 July 2025, and the serious-incident reporting template followed; the one Article 52(6) instrument, the register itself, did not. The Commission can also designate models on its own initiative (Article 51(1), point (b)); no public designation was located either. What circulates instead is third-party reconstruction from Epoch AI's compute estimates, which is what this table is, and says so.

A row appears when Epoch's point estimate of cumulative training compute clears 10²⁵ FLOP. These are estimates, not measured figures. Epoch labels each by confidence: “Confident” means within a factor of 3, “Likely” within a factor of 10, and “Speculative” within a factor of 30; the July 2025 GPAI Guidelines add a separate ±30% measurement tolerance on cumulative FLOP. Each value is copied exactly from the public database, carries Epoch's per-row vintage, and shows here at four significant figures. Crossing that line is not the same as sitting on the Union market: placement under Article 3 is a legal determination the public record does not settle per model, and two of these rows are unreleased per Epoch.

There is also a known direction to the undercount. Epoch estimates training compute, while Recital 111 directs that the cumulative total behind the Article 51(2) presumption count compute more broadly, “such as pre-training, synthetic data generation and fine-tuning”. A reconstruction built on the narrower measure marks a floor for the population the presumption reaches, not a census of it.

Nor does a row say anything about a provider's compliance. It is not a claim that the provider owed or missed a notification: Article 111(3) provides that “Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in this Regulation by 2 August 2027”. And it is not a claim that the presumption has survived, since Article 52(2) invites a provider to rebut it and any such rebuttal is as private as the notification itself. What a published register would resolve per model, this reconstruction cannot, which is the gap it documents.