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Transparency + possible High-Risk

Your AI features put you
in scope of the EU AI Act

If your SaaS product uses AI and serves EU customers, the EU AI Act applies — even if you're headquartered outside Europe. Most AI features trigger at least Article 50 transparency obligations in 74 days. Some may be high-risk with a 561-day deadline.

Most SaaS AI features need transparency compliance

Article 50 requires that users interacting with AI know they're interacting with AI. This applies to nearly every AI-powered SaaS feature.

Customer-facing chatbots

Any AI chatbot, virtual assistant, or support agent that interacts with EU users must disclose it is AI-powered

AI-generated content features

Text generation, code completion, email drafting, or any feature where AI creates content users may believe is human-written

AI image or video generation

Synthetic media features, avatar generators, or AI-created visuals must be labelled as AI-generated

Sentiment analysis & emotion detection

AI that analyses tone, emotion, or intent in user communications must inform users the analysis is happening

Some SaaS AI is also high-risk

If your AI makes or influences decisions about people in these categories, you face the full set of 10 high-risk obligations.

AI that scores, ranks, or filters job applicants (Annex III, point 4)
AI that evaluates creditworthiness or insurance risk (Annex III, point 5)
AI used to assess students or determine educational access (Annex III, point 3)
AI that affects access to essential public or private services (Annex III, point 5)

What's probably not in scope?

Not every feature with "AI" in the name triggers obligations. Pure rule-based systems and internal-only tools may be exempt.

Internal analytics dashboards with no direct user impact
A/B testing engines that vary UI elements
Rule-based automation (if/then logic, no ML models)
AI used purely for internal research not deployed to customers

Not sure? The free classifier takes 5 minutes and tells you exactly where your system falls.

Provider, deployer, or both?

Your role determines your obligations

If you build and ship the AI model, you're a provider — full obligations apply. If you integrate a third-party AI (OpenAI, Anthropic, etc.) into your product, you may be a deployer with lighter obligations — but you're still responsible for transparency, human oversight, and ensuring the system is used as intended. Many SaaS companies are both provider (of their product) and deployer (of the underlying model).

Read: Deployer vs Provider — which are you? →

Find out where you stand in 5 minutes

The classifier is free, no account required. Answer 6 questions and get your risk tier, applicable articles, and a clear next-steps checklist.