We only use a hosted API. Do we still have startup duties?

Yes, as the provider of the system you placed on the market (the chat UI, the agent, the image app). The API vendor has its own provider duties for the model. You do not inherit a waiver.

Is a sandbox a way out of Article 50?

No. Sandboxes (Articles 57–58) are supervised testing environments. They do not turn off transparency toward natural persons who interact with a production system.

EU AI Act for startups: a shipping-order checklist

A startup does not implement the entire AI Act in Q4. It implements the duties that already apply to the feature it sold: Article 50 transparency if people interact with the system or the system emits synthetic content; Article 5 if the feature is a prohibited practice; GPAI model duties if you trained or released a general-purpose model; and Annex III high-risk duties only if the feature actually sits there.

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.

A shipping order that matches the official timetable

First: inventory the AI features. Chat widget, image generator, résumé screener, support copilot. Second: run Article 2 (territorial). Third: attach Article 50(1) or 50(2)/50(4) to each feature that interacts or generates. Fourth: only then ask whether Annex III high-risk or GPAI systemic-risk chapters apply. That order stops a five-person company from writing an Annex IV file for a docs bot.

What “for startups” does not mean in the official text

Article 62 asks Member States to provide measures for SMEs, including start-ups (sandboxes, priority access, reduced fees for some conformity procedures). It does not waive Article 50. A twelve-person company with EU users still discloses a chatbot.

When the readiness report is the next step

If you have more than one AI feature, or you cannot tell provider from deployer, the free AI Law Check is the $0 filter. The $199 readiness report covers up to three AI features; $399 covers up to five products. That is an engineering gap analysis, not a substitute for counsel.

Questions teams ask

We only use a hosted API. Do we still have startup duties?: Yes, as the provider of the system you placed on the market (the chat UI, the agent, the image app). The API vendor has its own provider duties for the model. You do not inherit a waiver.
Is a sandbox a way out of Article 50?: No. Sandboxes (Articles 57–58) are supervised testing environments. They do not turn off transparency toward natural persons who interact with a production system.

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.