The word transparency hides four separate obligations in Article 50, and they do not all land on the same person. A shop that installs a chatbot is a deployer. The company that built the chatbot is a provider. Both have duties, but different ones. Here is how they split.
Provider obligations
Providers build or supply the AI system. Under Article 50 they must:
- Ensure systems that interact with people are designed so users are informed they are dealing with AI, unless it is obvious.
- Mark the output of generative systems (audio, image, video, text) as artificially generated, in a machine readable format where technically feasible.
Deployer obligations
Deployers put the system to use in their own context. They must:
- Disclose deepfake content they generate or manipulate as artificially produced.
- Disclose AI generated text published to inform the public on matters of public interest.
- Inform people exposed to emotion recognition or biometric categorisation that the system is in use.
Why this matters for a normal website
Most businesses are deployers. You did not build the chatbot or the image model, you use them. That means your practical job is disclosure at the point of use: a clear notice on the chat, a label on generated media, in the user's language, at the right moment. You are not expected to re engineer someone else's model, but you are expected to be transparent where your users meet the AI.
The qualities the law attaches
Every one of these disclosures has to be clear, timely (at the latest at first interaction or first exposure), and accessible. Get the content right but the timing or accessibility wrong and the obligation is not fully met.
Common questions
I use a third party chatbot. Am I a provider or a deployer?
A deployer. You deploy a system someone else provides. Your duty is the disclosure at the point of use.
Do both provider and deployer have to disclose the same chatbot?
The provider designs for disclosure. The deployer makes sure the notice actually appears to users in their context. In practice the visible notice is the deployer's responsibility.
Cover your deployer duties
The widget shows the interaction notice and content labels on your site, which is the deployer side of Article 50, from one snippet.
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