Can we push Article 50 onto the customer in the MSA?

You can allocate deployer 50(4) work by contract. You cannot contract out of being the provider of the system you designed and placed on the market. Article 25 (responsibilities along the value chain) is the official reminder that the chain does not erase the provider.

Does a private tenant with no EU seats take us out of Article 2?

For that tenant, maybe. For the product you still offer on a marketing site that EU companies can buy, you are still placing a system on the Union market. Scope is not “who paid this month.”

EU AI Act for SaaS: copilots, agents, and features you already shipped

SaaS AI is usually a dual-role problem. You place a system on the Union market (provider). Your customer turns it on against their users (they are a deployer; sometimes you are too). Article 2 still reaches a US-hosted multi-tenant app when EU users see the output.

Educational resource only — not legal advice. scm.cc publishes a readiness report and engineering gap analysis for AI features. It does not give legal advice, represent you before a regulator, or state that a product is ready to ship under any law. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.

Last checked against official sources: 2026-10-11.

Map each feature to a role

In-product copilot that your tenants’ end users chat with: you are the provider of an Article 50(1) system. You may also be the deployer if you operate the agent. Image or document generation inside the tenant workspace: you are the 50(2) provider; the tenant may be the 50(4) deployer when they publish. Hiring or credit modules: stop and read Annex III and the hiring-tools page — transparency is not the whole job.

Multi-tenant defaults that fail Article 50(5)

A single account-level “we use AI” checkbox from 2024 does not inform the natural person at first interaction. The disclosure has to appear where the person meets the system. Tenant admins can add extra wording; they cannot be the only people who ever see it.

California and Colorado on the same SaaS

If the same generative feature is available to Californians and you are the developer under § 3110, AB 2013 documentation is a website post, not an in-app banner. If the same feature ranks Coloradans for a job or a loan, SB26-189 notices start 1 January 2027. One product can owe all three.

Questions teams ask

Can we push Article 50 onto the customer in the MSA?: You can allocate deployer 50(4) work by contract. You cannot contract out of being the provider of the system you designed and placed on the market. Article 25 (responsibilities along the value chain) is the official reminder that the chain does not erase the provider.
Does a private tenant with no EU seats take us out of Article 2?: For that tenant, maybe. For the product you still offer on a marketing site that EU companies can buy, you are still placing a system on the Union market. Scope is not “who paid this month.”

Back to the AI law hub

Primary sources

Official text wins. Last checked 2026-10-11. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.