DepthThe conclusion and your first steps
Direct answer
We build an AI product for customers. What are a provider’s duties?
You describe: Your organisation develops an AI system (or has it developed) and places it on the market under its own name. Likely role: provider (you place the system on the market).
This applies now
- Article 50: transparencyApplicable
- Article 4: AI literacyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
As provider you carry the heaviest set of duties. If your system generates content, machine-readable marking (Article 50(2)) is your job. Classify early: high-risk determines your entire development and documentation process towards 2 December 2027.
Your first actions
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
- Justify the Article 6(3) exception against each individual condition. Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making.
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situation