Which EU AI Act transparency duties touch your product?
The high-risk deadline moved to December 2027. The transparency rules in Article 50 did not: they have applied since 2 August 2026 and reach ordinary products, a support chatbot or a "draft this for me" button, wherever the company is based. Eight yes-or-no questions give you your role for each feature, the duties with their dates and a one-page answer for the customer who asks.
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Your product
Prices in euros, a German or French version, EU case studies on the site all count as going after them. One stray sign-up from Lisbon doesn't. Free products count the same as paid ones.
Yes even if the model behind it is someone else's and you call it through an API. They provide the model; you provide the system built on it.
A "draft this for me" button, an image generator, a summariser, a voice-over. Tools that only assist with standard editing, such as a grammar fixer or a crop tool, are a no.
A realistic AI-generated "customer" in an advert is a yes. A company blog that a person reads and signs off is a no for the text part.
Scoring a caller's mood from their voice, or categorising people from a camera feed. Few small products do.
These are the Annex III areas. Screening CVs, ranking applicants, scoring exam answers and deciding who gets a loan are the common ways a small vendor lands here.
A support widget you bought, for example. The vendor is its provider; you are its deployer.
Where this comes from
The questions and dates follow our plain guide, the EU AI Act since August 2026: what a small software vendor actually has to do, which links the Regulation, the July 2026 amendment and the Commission's guidelines on Article 50. Read it for the exceptions this check leaves out, such as when it is "obvious" that someone is talking to AI.
If the AI in question is a support bot, the notice is the easy part. Whether the bot pays for itself is the support bot cost calculator's job.
Eight questions can't classify a product. The Act is long, the guidance is new and national authorities haven't yet shown how they'll apply it. For anything near the Annex III list, pay for an hour with someone who does this for a living. More free tools: biz59.net/tools.