If you build or deploy an AI product with EU users, this month matters.

On July 20, the European Commission published guidelines on the transparency obligations for AI systems. The obligations start applying August 2. Many founders assume "transparency" just means slapping "AI-generated" on a page. It's not that simple.

The question that actually trips up Chinese and other non-EU AI companies is one of identity: are you a provider or a deployer?

A provider develops the system and puts it on the market. A deployer runs the system under its own authority in its own service. Most companies wear both hats at once — and the obligations split by role:

→ Providers of chatbots must ensure users know they're talking to an AI.
→ Providers of generative AI must mark outputs in a machine-readable format.
→ Deployers of emotion-recognition or biometric-categorization systems must inform the people affected.
→ Deployers of deepfakes must disclose that content is artificially generated or manipulated.

Here's the part teams miss. I come from a computer-science background, so when I read "machine-readable marking," I know it means embedded metadata watermarks that detection tools can read automatically — not a small caption floating on your UI. Get the front-end copy perfect but the metadata wrong, and you're still non-compliant. This work sits in the gap between product and legal, and both sides tend to assume the other owns it.

Two quick myths worth killing:

"My users aren't in the EU, so I'm safe." If your product reaches EU users, extraterritorial application applies. Registering offshore doesn't get you out.

"I use a third-party model, so it's their problem." Your deployer-side duties — deepfake disclosure, emotion-recognition notice — stay with you. Push them into your vendor contract, but you still answer to regulators and users.

The one thing to do now: build a table listing every AI feature, then tag each with its category and your role (provider or deployer). Once that's clear, your obligation checklist writes itself — and you'll know what to change in the product and in your contracts.

August 2 isn't a distant deadline. It's this month.

Not sure whether you're a provider or a deployer, or whether your marking is truly machine-readable? Send me your product setup — happy to map it out first.

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Mike Wu, China-licensed Attorney · Cross-border practice
4 languages (CN/EN/ES/JA)
Site: wzklaw.com/contact.php?source=linkedin · Book consultation: wzklaw.com/contact.php?source=linkedin

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