Plenty of teams assume the AI Act only touches the labs that train large models. It does not. The moment you put an AI feature in front of users — even one built on someone else’s model — transparency obligations can apply. They are among the easiest duties to meet and the easiest to forget.
Transparency is about not deceiving people. If someone is talking to a machine, or looking at something a machine generated, they are entitled to know.
When transparency applies
Transparency duties attach to specific situations rather than to risk tier. The common triggers are systems that interact with people, systems that generate or manipulate content, and certain biometric or emotion-recognition uses.
Telling people they are dealing with AI
Where people interact with an AI system — a chatbot, a voice agent — they should be informed they are dealing with a machine, unless it is obvious from the context. The disclosure should be clear and timely, not buried in terms.
Marking synthetic content
AI-generated or manipulated audio, image, video or text — including deepfakes — generally needs to be marked as artificially generated. For users, that means a visible label; technically, it can also mean machine-readable marking so the provenance travels with the content.
Decide your labelling pattern once — wording, placement, and any machine-readable marker — and apply it consistently across every surface that ships generated content.
If you ship a general-purpose model
Providers of general-purpose AI models carry additional duties — including technical documentation, information for downstream providers, and a policy to respect copyright. If you only build on a third-party model, much of this sits with the upstream provider, but you should confirm what they supply.
Keeping records
Treat your disclosures as evidence: record where AI is used, what users are told, and how generated content is marked. When duties are spread across many features, a central register stops gaps appearing. Keep it with your other compliance records so nothing drifts out of scope unnoticed.
Key takeaways
- Transparency duties apply to deployers, not just model trainers.
- Tell people when they interact with AI, and mark AI-generated content.
- General-purpose model providers carry extra documentation and copyright duties.
- Keep a register of where AI is used and what you disclose.
Not sure which features trigger disclosure? Book a 30-minute demo.
This article is general guidance, not legal advice. Verify obligations and deadlines for your organisation with qualified counsel.