AI Oversight: Global Regulatory Tracker – European Union

AI Oversight: Global Regulatory Tracker – European Union

January 19, 2025

 

The EU launches the groundbreaking EU AI Act, striving to establish itself as a leading center for human-centered, reliable AI.  This is a brief article covering areas of the Act.  This article is intended to provide general information for interested readers. It is not comprehensive and should not be considered as legal advice due to its general nature.  Please refer to the link for recent laws and regulations governing AI (the “AI Regulations”)

 

The main legislative framework for AI regulation in the EU is the EU AI Act (here). Additionally, the EU has proposed the AI Liability Directive (here), aimed at ensuring that liability rules are effectively applied to claims related to AI.

 

Status of AI Regulations

 

The EU AI Act, recognized as the first comprehensive regulatory framework for artificial intelligence within the European Union, was officially published in the EU Official Journal on July 12, 2024. This legislation will take effect on August 1, 2024, but its provisions will not be enforceable until August 2, 2026, with certain exceptions specified in Article 113.

 

Currently, the AI Liability Directive remains in draft form and has yet to be reviewed by the European Parliament and the Council of the EU, leaving its timeline uncertain. Additionally, on September 5, 2024, the Council of Europe’s Framework Convention on AI was signed by several countries, including Andorra, Georgia, Iceland, Norway, the Republic of Moldova, San Marino, the United Kingdom, Israel, the United States, and the European Union. This treaty will come into effect after five signatories, including three from the Council of Europe, ratify it, and will be open to countries globally that wish to abide by its principles.

 

A variety of existing laws in the EU may impact AI development and usage, including:

 

• The EU General Data Protection Regulation (EU) 2016/679

• The forthcoming Product Liability Directive, which, if passed, will enable individuals harmed by AI software to seek compensation from manufacturers

• The General Product Safety Regulation 2023/988/EU, which updates previous directives

• Various intellectual property laws specific to each EU Member State.

 

Definition of AI

 

The EU AI Act defines “AI” with several key terms:

 

• An “AI system” is a machine-based system designed to operate with different levels of autonomy and may adapt after deployment, generating outputs such as predictions or recommendations based on its received inputs.

• A “general-purpose AI model” refers to an AI model capable of performing diverse tasks, provided it is not solely used for research or development prior to market entry.

• A “general-purpose AI system” is built on a general-purpose AI model and can serve multiple functions, either directly or integrated into other AI systems.

 

The AI Liability Directive is expected to adopt similar definitions as the EU AI Act.

 

Territorial and Sectoral Scope

 

The EU AI Act has extraterritorial applicability, affecting:

• Providers offering AI systems or general-purpose models in the EU market, regardless of their location.

• Deployers of AI systems established within the EU.

• Providers or deployers located outside the EU, if their AI outputs are intended for use within the EU.

• Conversely, the AI Liability Directive is relevant for non-contractual civil law claims made within the EU.

 

Both the EU AI Act and the AI Liability Directive are broad in scope, as they apply to all sectors without limitation.

 

Roles and Compliance Under the EU AI Act:

 

• Developers of AI systems or models, along with various stakeholders including public authorities, are designated as “providers.”

• Entities involved in the supply chain, excluding providers or importers, are termed “distributors.”

• Those who market AI systems bearing the name of a foreign entity are recognized as “importers.”

• Users of AI systems, excluding personal non-professional use, are classified as “deployers.”

• The term “operators” encompasses all parties involved, including providers, manufacturers, and distributors.

• Each role entails specific compliance responsibilities, with the AI Liability Directive enhancing the likelihood of successful claims against AI system developers or users.

 

Core Objectives

 

The EU AI Act aims to foster trustworthy AI while ensuring high protection standards for health, safety, rights, and democracy against the risks posed by AI technologies. The AI Liability Directive seeks to afford individuals harmed by AI systems the same protections as those injured by other technologies, addressing the difficulties of proving liability due to the complex and autonomous nature of AI.

 

Risk Assessment and Compliance Requirements

 

The AI Act categorizes AI systems into four risk levels, establishing varied compliance requirements:

 

• Unacceptable Risk: These systems are prohibited entirely, including those employing social scoring or deceptive practices.

• High Risk: Subjected to rigorous compliance, these systems must be registered before market entry and adhere to extensive requirements regarding data training, documentation, human oversight, and security.

• Limited Risk: Systems that interact with individuals (such as chatbots) must follow transparency obligations.

• Low/Minimal Risk: Any AI not fitting the above categories faces no specific compliance requirements.

• The Act also introduces codes of conduct intended to be voluntarily adopted by AI providers.

 

Regulatory Framework

 

The enforcement of the EU AI Act involves collaborative oversight by national authorities appointed by EU Member States, responsible for maintaining compliance and conducting assessments. A dedicated AI Office within the European Commission will support enforcement efforts, complemented by scientific experts and a Board representing Member States to ensure consistent application of the regulations.

 

Additionally, national courts will oversee the implementation of the AI Liability Directive related to civil law claims.

 

Enforcement and Penalties

 

Market surveillance authorities are empowered to act if AI systems do not comply with regulations or pose risks despite compliance. They can mandate corrective actions or restrict market access for non-compliant AI systems.

 

Penalties for violations can be substantial, with fines reaching up to €35 million or 7% of a company’s global turnover for serious breaches, while lesser penalties may apply for misleading information submissions.

 

The AI Liability Directive creates a rebuttable presumption of causation, simplifying the process for claimants in proving liability related to AI system damages, and grants courts powers to demand evidence disclosure for high-risk AI systems implicated in harm.

 

 

Notes and references:

1.  EU AI Act, Article 113.

2.  Procedure File: 2022/0303(COD) | Legislative Observatory | European Parliament (europa.eu).

3.  Convention text here. 

4.  European Commission press release here.

5.  EU AI Act, Articles 3(1), 3(63) and 3(66).

6.  AI Liability Directive, Article 2(1).

7-8.  EU AI Act, Articles 2(1)(a) to (c). Responsibilities along the AI value chain (including distributors, importers, deployers) are set out in Article 25, EU AI Act, Recital 22.

9.  AI Liability Directive. Article 1(2).

10-14.  EU AI Act, Article 3(3), 3(7), 3(6), 3(4), 3(8).

15.  AI Liability Directive, Article 4(b).

16.  “Purpose” in the Procedure File at printficheglobal.pdf (europa.eu); and EU AI Act, Article 1(1).

17.  EU AI Act, Recital 179

18.  EU AI Act, Article 5.

19.  EU AI Act, Article 6(1), (2) and Annex I, Annex III. 

20.  EU AI Act, Articles 50(1) to 50(4).

21.  EU AI Act, Article 50(4).

22.  page 4 of the briefing note.

23.  EU AI Act, Article 51.

24.  EU AI Act, Articles 8-15 and 49.

 

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Memory Requirements for AI Training

The Graphics Processing Unit (GPU) constitutes a fundamental component in the realm of Large Language Model (LLM) training, primarily owing to its capability to expedite parallel computations. Contemporary deep learning frameworks such as TensorFlow and PyTorch capitalize on GPUs to execute matrix multiplications and other requisite operations essential for neural network training. In the selection process of a GPU, pivotal considerations encompass memory capacity (Video Random Access Memory or VRAM), memory bandwidth, and processing power, quantified in terms of CUDA cores. High-tier GPUs like NVIDIA’s Tesla series or the GeForce RTX series are commonly preferred for LLM training endeavors, given that heightened GPU potency correlates with swifter training processes. This article will cover several GPU cards and calculations.

Data Center GPU Offerings

Herein are delineated some of the most potent, data center-grade GPUs globally, commonly deployed for erecting extensive GPU infrastructure.

  • NVIDIA Tesla A100
    • The A100, predicated upon Tensor Cores, harnesses multi-instance GPU (MIG) technology. Engineered for workloads spanning high-performance computing (HPC), machine learning, and data analytics, the A100 emphasizes scalability, accommodating up to thousands of units. It can be subdivided into seven GPU instances catering to diverse workload scales. The A100 delivers performance peaking at 624 teraflops (trillions of floating-point operations per second) and encompasses 40GB of memory, 1,555 GB bandwidth, and 600GB/s interconnects.
  • NVIDIA Tesla V100
    • Built upon Tensor Cores, the V100 GPU is tailored for applications including machine learning, deep learning, and HPC. Leveraging NVIDIA Volta technology, the V100 expedites common tensor operations inherent in deep learning workloads. The Tesla V100 proffers performance scaling up to 149 teraflops, alongside 32GB of memory and a 4,096-bit memory bus.
  • NVIDIA Tesla P100
    • The Tesla P100 GPU, grounded in an NVIDIA Pascal architecture, is expressly crafted for HPC and machine learning pursuits. Endowed with a performance potential of up to 21 teraflops, the P100 integrates 16GB of memory and a 4,096-bit memory bus.
  • NVIDIA Tesla K80
    • The K80 GPU harnesses NVIDIA Kepler architecture, facilitating the acceleration of data analytics and scientific computing. Embodied within are 4,992 NVIDIA CUDA cores, along with GPU Boost™ technology. The Tesla K80 furnishes performance capabilities reaching up to 8.73 teraflops, complemented by 480GB memory bandwidth and 24GB of GDDR5 memory.
  • Google TPU
    • Google proffers distinct tensor processing units (TPUs), which constitute application-specific integrated circuits (ASICs) deployed either in chip form or within the cloud, to bolster deep learning endeavors. Tailored explicitly for utilization with TensorFlow, these TPUs are exclusively accessible on the Google Cloud Platform. Google TPUs deliver performance metrics scaling up to 420 teraflops, coupled with a high bandwidth memory (HBM) of 128 GB. Additionally, pod versions boasting over 100 petaflops of performance, alongside 32TB HBM and 2D toroidal mesh networks, are available.

Commodity GPUs encompass a mere 16 GB / 24 GB of GPU memory, while even the most advanced NVIDIA A100 and V100 GPUs are endowed with 40 GB / 80 GB of GPU memory per device.

Calculation of Required A100 GPUs for LLM Training

To determine the requisite number of A100 GPUs for LLM training, the following formula is applied:

Number of A100 (80G) GPUs needed for Training = ((tokens * epochs * model_size * 13.3) / hours)

Calculation of Required A100 GPUs for LLM Inference

The formula employed for computing the necessary number of A100 GPUs for LLM inference is as follows:

Number of A100 (80G) GPUs needed for Inference = (output_tokens / throughput * qpm / 60)

Model Memory Calculator

A tool facilitating the computation of the requisite vRAM for training and conducting inference on substantial models hosted on the 🤗 Hugging Face Hub is available.

Best Practices for Effective Distributed LLM Training

Implementing effective distributed systems in LLM training necessitates adherence to the following best practices:

1. Framework Selection: Opt for frameworks purpose-built for distributed training such as TensorFlow or PyTorch, offering streamlined tools and APIs for the implementation of distributed training strategies.

2. Communication Optimization: Minimize communication overhead by adopting techniques like gradient accumulation prior to model updates or employing gradient compression to diminish data exchange between nodes.

3. Batch Size Experimentation: Identify the optimal batch size for distributed training, considering that excessively small batches might amplify communication overhead, while overly large batches can engender memory constraints.

4. Monitoring and Tuning: Routinely monitor distributed training performance and adjust hyperparameters, partitioning strategies, and communication settings to optimize efficiency.

5. Backup and Recovery Mechanisms: Implement robust mechanisms for periodic model checkpoints and swift recovery in the event of failures, ensuring seamless resumption of training without necessitating recommencement.

Challenges of Distributed LLM Training

While distributed systems furnish notable advantages in expediting LLM training, they concurrently pose challenges that demand mitigation:

1. Communication Overhead: In distributed systems, communication between nodes can emerge as a bottleneck, particularly during gradient aggregation or model update exchanges, thereby potentially impeding overall speedup.

2. Synchronization Complexity: Coordinating updates from multiple machines, especially in model parallelism scenarios, entails intricate synchronization to ensure accurate alignment of diverse model segments.

3. Failure Handling: The advent of individual node failures in distributed systems underscores the necessity for robust mechanisms facilitating failure recovery and seamless resumption of training processes.

4. Resource Management: Efficiently managing resources across multiple machines, encompassing both CPUs and GPUs, mandates sophisticated resource allocation and scheduling strategies.

References:

  1. https://lambdalabs.com/gpu-benchmarks
  2. https://towardsdatascience.com/how-to-build-a-multi-gpu-system-for-deep-learning-in-2023-e5bbb905d935
  3. https://huggingface.co/docs/accelerate/main/en/concept_guides/training_tpu
  4. https://docs.nvidia.com/deeplearning/performance/dl-performance-gpu-background/index.html
  5. https://huggingface.co/docs/accelerate/main/en/usage_guides/model_size_estimator
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