Quite possibly — but usually only the light-touch transparency duties, not the heavy “high-risk” regime. Being small doesn’t exempt you; what matters is your role and whether your users are in the EU.
The rules follow what you do. A provider builds an AI system and puts it out under their own name; a deployer simply uses one. Most small businesses are deployers, which usually means only the limited Article 50 transparency duties rather than the heavy high-risk regime. Two things to watch, though. If you use AI for recruitment, credit decisions or managing staff, you may be deploying a high-risk system, which carries extra duties under Article 26 from 2 December 2027. And every provider and deployer, whatever they use AI for, has to take measures supporting AI literacy among staff under Article 4.
Using an off-the-shelf tool to write copy generally makes you a deployer — usually with no transparency duty, unless you’re running a customer-facing bot or publishing public-interest content — though the Article 4 AI-literacy duty applies either way. It does not pull you into the high-risk rules.
It can still apply. If your AI or its outputs reach people in the EU, you’re in scope — the same long-arm logic as the GDPR. (A business in Brazil or the US whose chatbot serves customers in the EU is in scope; a business established inside the EU is in scope wherever its customers are.)
Building on a free or open model doesn’t switch off the Article 50 transparency duties.
Startups face the same duties. The concessions are lighter paperwork and proportionate enforcement — not exemption. If you build or rebrand AI as your own product, you may tip into being a provider, with heavier duties.
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