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Knowledge · As of 2026-09-07

EU AI Act: which obligations apply to SMEs?

The EU AI Act has no SME exemption: since 02 Feb 2025, every company using AI must take measures to support AI literacy (Article 4; since the Digital Omnibus without a prescribed level); since 02 Aug 2026, transparency obligations for chatbots and generative AI apply (Article 50). The scope of all further obligations depends on the risk class of your AI systems - not on company size.

The deadlines

The regulation phases in. Four dates matter in practice:

SinceObligation
02 Feb 2025Prohibited practices and Article 4: AI literacy for all companies using AI
02 Aug 2025Obligations for GPAI model providers, governance and penalties
27 Jul 2026Digital Omnibus (Regulation (EU) 2026/1744) in force: Article 4 requires measures instead of a set level, high-risk deadlines postponed
02 Aug 2026General applicability incl. transparency (Article 50): label AI chatbots, disclose deepfakes
02 Dec 2027High-risk obligations under Annex III (e.g. recruiting, credit scoring)
02 Aug 2028High-risk obligations for AI in regulated products

What this means for a typical SME

Most mid-sized companies run limited- or minimal-risk AI: chatbots, assistants, generative tools. For those: label AI interaction and take documented AI literacy measures in the team - in many cases, that is it. It gets serious with high-risk applications under Annex III (recruiting, credit scoring, critical infrastructure): from 02 Dec 2027, risk management, data quality, documentation, and human oversight apply.

Fines reach €35 million or 7% of global turnover for prohibited practices, €15 million or 3% otherwise. The pragmatic roadmap: inventory your AI systems, classify them, document your Article 4 measures (an AZAV-certified training is fundable in Germany), write an AI policy, review yearly.

Frequently asked questions

Does the AI Act apply if we only use ChatGPT?

Yes. Pure users have had to take AI literacy measures in the team since 02/2025 (Article 4). Provider obligations do not apply to you as a user.

Do we have to label our website chatbot?

Yes - since 02 Aug 2026, Article 50 requires that users can recognize AI interaction unless it is obvious. One sentence in the chat window usually suffices.

Read next

AI COMPLIANCE: our services →Article 4 trainings (fundable) →

Factual summary, as of 10/2026 after the Digital Omnibus (Regulation (EU) 2026/1744) - not legal advice.