Guide

AI automation and the EU AI Act: disclosure requirement

Since August 2026, the EU AI Act transparency obligations apply. What that means in practice for AI automation, who it affects, and what actually needs to be done in implementation.

Quote on request4 to 8 weeksAs of 2026
In short

Since August 2026, the transparency obligations from Article 50 of the EU AI Act apply: anyone communicating directly with an AI system must be able to recognize it. We build in the disclosure by default. For AI automation, that means: disclosure is mandatory, not optional, and applies regardless of company size — a sole proprietorship is just as affected as a corporation. What matters is the purpose and risk, not headcount.

01 — Legal situation

EU AI Act: what applies

Since August 2026, the transparency requirements from Article 50 of the EU AI Act apply: Anyone communicating directly with an AI system must be able to recognize it. We build in the labeling as standard.

The AI Act doesn't distinguish by company size: A sole proprietorship with an AI system in customer contact is affected just as much as a corporation. What matters is purpose and risk, not headcount.

There's also the obligation to ensure adequate AI competence for the people working with it. That's not an examination requirement, but it should be documented — a training session with a participant list is the simplest proof.

02 — Data protection

What GDPR requires

As soon as personal data is processed — and that happens faster than expected, for instance as soon as someone enters a name or phone number — the usual obligations apply: name the legal basis, define the purpose, maintain data minimization, define retention periods, inform data subjects.

In practice, that means for AI automation: a data processing agreement with every involved service provider, checking where processing takes place, a documented deletion period, and clear language in the privacy policy. Three things are almost always missing in practice: the defined deletion period, the notice at the point where data is collected, and clarification of whether the provider uses the data for its own training.

A data protection impact assessment is only required when there's likely high risk — not for most projects of this type. The review itself should still be documented so that if questions arise, it's clear why it was omitted.

03 — Risks

What can go wrong

  • The system answers incorrectly. Containable by having it work exclusively from verified content and escalate when uncertain rather than guess. This is a configuration decision, not a property of the technology.
  • The effort is underestimated. Most common reason: unclear starting situation. An honest assessment of the current state before the proposal prevents this more reliably than any buffer.
  • No one maintains it. The biggest risk of all — and the most easily avoidable.
  • Data protection gaps. Almost always arise from missing deletion deadlines and unclear responsibility, rarely from the technology itself.
  • Vendor lock-in. Avoidable if access credentials, data, and documentation contractually remain with the client.

04 — Questions

Frequently asked questions

What's the difference from regular automation?

Regular automation follows fixed rules: if field A is filled, do B. AI automation comes into play where there are no fixed fields — free text, images, changing document formats. The right answer is usually both together, not one or the other.

How does this differ from a chatbot?

A chatbot answers questions in dialogue. AI automation runs in the background without conversation — it reads, categorizes and pre-decides while someone else is focused on the actual work.

Does our data end up in a language model's training?

No. We exclusively use access where training with customer data is contractually excluded, and we process in the EU. For particularly sensitive data, we use models that run on your own infrastructure.

Can we start small?

That's the only sensible approach. One use case, eight weeks, measurable outcome. What comes next, you decide based on what you've seen.

What does the EU AI Act say about this?

Most business use cases fall into the low-risk category and primarily trigger transparency obligations. Where customers interact directly with the system or AI-generated content is published, we label it. For applications in HR, we look more closely — stricter rules apply there.

What if the documents or formats change?

As long as the content meaning stays the same, the system handles it well — unlike rigid, field-based recognition. Fundamentally new document types need brief adjustment, not a rebuild.

How reliable is it?

That depends on the use case, and we measure it before anything goes live. For classifying incoming messages, well-built systems regularly exceed ninety percent. What matters isn't the rate alone, but what happens when there's an error — that's why we always build in a confidence threshold.

Next step

Initial assessment, no obligation.

Briefly describe what you need. You'll get an honest answer about what's realistic and what it will roughly cost.