Since 2 August 2026, the transparency obligations under the EU AI Act have applied. They affect every company whose employees use AI chatbots for work purposes. This is because the company itself\u2014not the individual employee\u2014is considered the deployer under the AI Act.<\/p>\n
\ud83d\udd0d The key requirements of Article 50 of the AI Act in the HR context:<\/p>\n
\u27a1\ufe0f Published AI-generated texts on matters of public interest must be labelled using a symbol and\/or a notice.<\/p>\n
\u26a1 However, this requirement does not apply if the AI-generated texts have undergone substantive human review\u2014not merely a spelling check\u2014and have been revised where necessary, provided that the company assumes editorial responsibility for them.<\/p>\n
\u27a1\ufe0f Deepfakes must always be disclosed, including in job advertisements and employer-branding content. A notice in the legal disclosure or imprint is not sufficient.<\/p>\n
\u27a1\ufe0f The use of emotion-recognition and biometric-categorisation systems\u2014for example, in HR tools\u2014must be disclosed to the individuals concerned (Article 50(3) of the AI Act).<\/p>\n
\u2705 To-dos for employers:<\/p>\n
\u27a1\ufe0f Create an inventory of AI systems and identify relevant workflows within HR management.<\/p>\n
\u27a1\ufe0f For each AI system in use, determine whether the company qualifies as a provider or a deployer, as the respective obligations differ considerably.<\/p>\n
\u27a1\ufe0f Train employees in accordance with their roles and responsibilities. The AI-literacy obligation under Article 4 of the AI Act has already applied since February 2025.<\/p>\n
\u27a1\ufe0f Define internal responsibilities and ensure appropriate documentation.<\/p>\n
\u26a0\ufe0f Breaches of the transparency obligations may result in fines of up to \u20ac15 million or 3% of worldwide annual turnover, as well as cease-and-desist claims under competition law.<\/p>\n
P.S. The first draft of this post was written by Claude (Anthropic). Since I substantially revised it and assume editorial responsibility for it, THIS notice would not be required under Article 50 of the AI Act. \ud83d\ude0a<\/p>\n","protected":false},"excerpt":{"rendered":"
Since 2 August 2026, the transparency obligations under the EU AI Act have applied. They affect every company whose employees use AI chatbots for work purposes. This is because the company itself\u2014not the individual employee\u2014is considered the deployer under the AI Act. \ud83d\udd0d The key requirements of Article 50 of the AI Act in the…<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-9375","post","type-post","status-publish","format-standard","hentry","category-unkategorisiert"],"yoast_head":"\n