I sell into the EU and run an AI chat on my store. Does the AI Act reach me?
Article 50 applies from August 2, 2026. Read your chat’s disclosure, identify its supplier, and ask who holds the legal duty.
- When this applies
- Your storefront runs an AI chat or shopping assistant, or publishes AI-generated images or copy, and customers in the EU can reach it. [1]
- When this does not apply
- Article 50(1) assigns chatbot disclosure to the provider: whoever develops or commissions the system and places it on the EU market or puts it into service under its own name or trademark. Ask a lawyer which role your business holds. [1]
- Why this matters
- The obligations applied from August 2, 2026, they reach providers established outside the EU where the output of the system is used in the EU, and enforcement carries fines of up to 15 million euros or 3% of total worldwide turnover. [1]
- What to do
- Open your store signed out and read the chat’s first message. Ask the supplier who holds the provider role and which disclosure it relies on. [1]
- When you’re done
- You can name the supplier of every AI system a customer can interact with on your store, and you have read for yourself what each one says at the start of a conversation. [1]
- What this cannot prove
- Reading your own chat proves what it said on the day you read it. It does not establish who the law treats as the provider in your case, and nothing here is legal advice. [1]
- Sources checked
- October 12, 2026
- Changed
- August 2, 2026
Paid help and free options
- When paid help makes sense
- Paid help is worth it for the one question a blog cannot answer, which is whether your business is the provider or the deployer of the assistant you run, because that answer decides which duties are yours. [1]
If EU shoppers can use your store’s AI chat, read its opening message and ask the supplier who owns the disclosure duty. Article 50 has applied since August 2, 2026. Your legal role needs legal advice.
Check who supplies the system
The Commission’s Article 50 FAQ distinguishes:
- Provider: develops or commissions the system and markets or puts it into service under its own name or trademark. Article 50(1) requires providers to design direct interaction so people know they are dealing with AI, unless obvious.
- Deployer: professionally uses a system under its authority. Listed duties include emotion recognition or biometric categorization notices, deepfake disclosures, and labeling AI text published to inform the public on matters of public interest.
Embedding a vendor-branded widget and commissioning your own branded assistant can create different roles. Ask a lawyer how your contract fits these definitions. Providers outside the EU are also covered when their system’s output is used there.
Read the first interaction
The interaction duty requires all four: an AI system, genuine two-way exchange, direct communication without a human intermediary, and interaction with people. Background machine-to-machine systems are outside it.
Where applicable, the notice must appear at the start of the first interaction, be clear and distinguishable, and meet accessibility requirements. The “obvious” exception is assessed against a reasonably informed, careful person and interpreted narrowly.
Open the store signed out, start the chat, and record the first message. Ask the supplier who it considers the provider and which notice it relies on. Ask the supplier of AI-generated images or copy about content marking too.
Keep the dates separate
Only the Article 50(2) marking/detection duty for systems marketed before August 2, 2026 has a grace period to December 2, 2026. Content generated before August 2, 2026 needs no retroactive label, though the Commission encourages one where possible.
The regulatory framework records the AI Omnibus taking effect July 27, 2026: Annex III high-risk cases move to December 2, 2027, and regulated-product systems to August 2, 2028. Transparency remains August 2026.
National market surveillance authorities mainly enforce these duties. Fines can reach €15 million or 3% of preceding-year worldwide turnover; proportionality can apply to SMEs and small mid-cap companies (SMCs).
Finish with a supplier list and the opening disclosures you observed. This confirms what the store said on that date; it establishes neither your legal role nor compliance. This Answer is not legal advice.