05 / OBSERVATORY · LICENSES Back to home

A guide to open-model licenses.

“Open” does not mean “free for any use”. Before putting a model in a paid service, a hospital or a public body, you must read the license. Here is how we classify them.

Updated September 2026
Updated September 2026
01 / CATEGORIES

Five buckets, from green to red.

Category, examples, what you can do.

01Green light (MIT, Apache 2.0)

DeepSeek V4, GLM-5.2, Qwen3.5, Mistral Large 3 and Ministral 3, gpt-oss, Gemma 4, Granite, Velvet, Minerva, Omnilingual ASR, MADLAD-400, Sunflower, TerraMind and Prithvi

commercial use, modification, on-site installation

02With conditions

Llama (user threshold and use policy), N-ATLaS (license beyond 1,000 users per month), Liquid AI LFM (free under $10 M revenue), Kimi K3 and GLM-5.3 (own terms)

commercial within the limits; read the terms

03Healthcare with constraints

MedGemma, MedASR, TxGemma (HAI-DEF terms)

research and products, but clinical use only after authorization as a medical device

04Research only

NLLB-200, MMS, Seamless, InkubaLM, the Aya family, UNI, CONCH, Virchow, Aurora

no commercial use without a separate agreement

05Avoid in the EU

Llama 4

the license places limits on entities based in the EU

02 / SURROUNDING SOFTWARE

The license of the wrapper too.

The model is one thing; the interface around it is another.

The software around the model has its own license too. Open WebUI, for example, beyond 50 users imposes its own brand; LibreChat and AnythingLLM (MIT) do not.

03 / AI ACT

The AI Act in brief.

Who is responsible, and when the obligations start.

Obligations on general-purpose models remain with the model providers. Whoever sells an AI system under their own brand becomes its provider; for high-risk uses (access to care, public services, education) obligations apply from 2 December 2027. The obligation to tell the user they are talking to an AI applies from 2 August 2026. With the Digital Omnibus, in force from 27 July 2026, the staff literacy obligation (art. 4) became “adopt measures to support it”.

This page is for informational purposes and does not constitute legal advice.