Guide

AI Training and the EU AI Act: Labeling Requirement

The transparency obligations of the EU AI Act have been in effect since August 2026. What this means specifically for AI training, who is affected, and what actually needs to be done in implementation.

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In short

The transparency obligations from Article 50 of the EU AI Act have been in effect since August 2026: Anyone communicating directly with an AI system must be able to recognize it. We build in the labeling as standard. For AI training, this means: Labeling is mandatory, not optional, and applies regardless of company size — a sole proprietorship is affected just as much as a corporation. What matters is 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, this means for AI training: a data processing agreement with every service provider involved, checking where processing takes place, a documented deletion period, and a clear section 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

Won't that be outdated after three months?

The tools change, the mindset doesn't. The focus is on when such a system is appropriate and how you verify its output — that remains valid even if the interface looks different.

Can we do this online as well?

Yes, then usually in two half-days instead of one full day — concentrated screen work over eight hours doesn't work well.

Do our people need prior knowledge?

No. We start from zero and divide the exercises according to prior knowledge. Experience shows that every team has both extremes.

What if individual employees don't want to?

That happens and it's not a disaster. We train everyone equally, but no one is forced to use it — experience shows that changes on its own once colleagues see the benefits.

Does the EU AI Act require training?

For businesses that use AI systems, there is an obligation to ensure adequate AI competency among the people working with them. A documented training is the easiest way to demonstrate compliance.

Do we get materials?

Yes: the slides, a collection of proven prompts for your tasks, and the usage policy as an editable document.

Is this also useful for executives who don't do much typing themselves?

Yes, for a different reason: They need to be able to assess where these tools make sense in the team and where risks lie — that's independent of whether they work with them daily themselves.

05 — Next

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