If you sell to the EU or the UK
A US brand is not exempt just because its servers and its founders sit in Austin. If you sell to people in Europe, their rules follow the shopper.
The EU AI Act
The European Commission’s AI Act Service Desk says in its FAQ that the transparency obligations in Article 50 apply from 2 August 2026. The same page says providers of systems placed on the market before that date have until 2 December 2026 to comply with the marking and detection duty in Article 50(2), and that the Annex III high-risk rules apply from 2 December 2027.
For a store, the part that bites first is the duty to tell people when they are dealing with an AI system. The law firm Travers Smith explains that providers of systems that interact directly with people must ensure those people know it is AI, and that this reaches chatbots, AI voice assistants and agentic systems that contact individuals on their own. The information must be clear, given at the latest at first interaction, and meet accessibility requirements.
In practice: a visible label at the start of the chat, in words a person actually reads, and not a line buried in the terms.
The UK
The UK route runs through consumer law. The GOV.UK guidance advises you to consider labeling an AI agent so customers are not misled into thinking a real person serves them, and to tell them when knowing it is AI could change their decision. It also warns against overstating what the AI can or cannot do. On penalties, it says breaches of consumer protection law can bring enforcement action, fines of up to 10% of worldwide turnover, and compensation for affected consumers.
Side by side
|
US |
EU |
UK |
| Main source of duties |
State laws on chatbot disclosure and consumer protection |
EU AI Act, plus GDPR |
Consumer law, plus UK GDPR |
| Tell people it is AI |
Required in several states, with different triggers |
Article 50, from 2 August 2026 |
Advised where it could affect decisions |
| Who is covered |
Stores selling to residents of those states |
Stores serving people in the EU |
Stores serving people in the UK |
| Where to check |
Each state’s current statute |
AI Act Service Desk |
GOV.UK guidance |
The common thread is easy to remember: say it is AI, early and plainly.