25 AI models have been trained with more than 10²⁵ FLOP, the EU AI Act's systemic-risk threshold; 18 are American

What the chart shows

The EU AI Act presumes that a general-purpose model trained with more than 10²⁵ FLOP poses systemic risk, which brings extra duties. Epoch AI counts 25 models above that line so far: 18 from US organisations, 5 from Chinese ones and 2 from elsewhere.

The first was Gemini 1.0 Ultra (2023); 7 have been released in 2026 so far. Many of these figures are Epoch’s estimates, because developers rarely publish their training compute.

Key numbers

How to read it

• Models with an Epoch AI training-compute estimate above 10²⁵ FLOP, from its large-scale models database; a model from organisations in several countries counts once for each group.
• The EU AI Act threshold is in Article 51; the Commission can change it.
• The current year is incomplete.