AI Transparency Obligations: What You Must Disclose to Users

Transparency is the minimum bar

Even if your AI SaaS is low-risk, the AI Act still requires transparency. Article 50 applies to virtually all AI systems that interact with humans.

Here's exactly what you need to disclose, and where.

1. AI disclosure notice

Where: On your website (footer or about page) and in your product UI.

What to say:

"This product uses artificial intelligence to [describe function]. AI outputs are reviewed by humans before [action] is taken. For questions about our AI usage, contact [email]."

Why it matters: Failing to disclose AI interaction is the most common compliance gap we find in scans.

2. Privacy policy AI section

Where: Privacy policy, add a dedicated "AI and Automated Decision-Making" section.

What to include:

• Description of what the AI does
• What data feeds the AI model
• Whether decisions are automated or human-reviewed
• User rights: ability to opt out, request human review, appeal decisions
• Data retention for AI logs

3. In-product AI labeling

Where: Anywhere the user interacts with AI output.

Examples:

• Chatbot: "AI-generated response" label
• Content tool: "AI-generated" badge
• Recommendation engine: "Recommended by AI" notice
• Analytics: "AI-predicted value" annotation

4. Model documentation

Where: Internal (not public), but ready for regulatory review.

What to document:

• Model name and version
• Provider (OpenAI, Anthropic, open-source, custom)
• Training data sources and cutoff date
• Known limitations and biases
• Accuracy metrics (if available)
• Date of last evaluation

5. User rights communication

Where: Product UI and documentation.

What to communicate:

• Right to know they are interacting with AI
• Right to opt out of AI processing (where feasible)
• Right to human review of AI decisions that affect them
• Right to appeal or contest AI decisions

Common transparency mistakes

• No AI disclosure at all (most common — 60% of AI SaaS we scan)
• Generic disclosure ("We use AI") without specifics
• Buried disclosure in TOS pages nobody reads
• No in-product labels — users don't know they're talking to AI

Quick win: add AI disclosure today

You can add an AI disclosure notice to your website footer in 10 minutes. It's the single highest-impact action for AI Act readiness.