Guides · Article 50 · EU AI Act
Does the EU AI Act apply to US companies?
A common question from US teams is whether the EU AI Act — and its Article 50 transparency obligations — can reach a business based outside the EU. In general terms, the Act is designed to have effect beyond the EU's borders, so a US-based provider or deployer can fall within its scope depending on the facts. This guide gives a general, hedged overview. It is informational only, not legal advice, and does not decide whether the Act applies to you.
Why location alone may not decide it
The EU AI Act is broadly understood to apply not only to organisations established in the EU but also, in defined circumstances, to organisations outside the EU whose AI systems are placed on the EU market or whose outputs are used in the EU. In other words, being headquartered in the United States does not by itself place a company outside the Act. Whether your specific situation is caught depends on facts like where your users are, how your system is made available, and how its outputs are used — questions to confirm with qualified counsel rather than assume.
What Article 50 would ask of you if it applies
If Article 50 applies, the transparency duties themselves do not change based on where you are incorporated. They turn on the type of AI system. Providers of systems that interact directly with people, or that generate synthetic content, and deployers of emotion-recognition or deepfake systems, each have their own paragraph. Article 50's transparency obligations apply from 2 August 2026.
- Article 50(1) — providers: inform people they are interacting with an AI system, subject to the 'obvious' exception.
- Article 50(2) — providers: mark synthetic audio, image, video, or text as artificially generated in a machine-readable format.
- Article 50(3) — deployers: inform people exposed to emotion-recognition or biometric-categorisation systems, and follow EU data-protection law.
- Article 50(4) — deployers: disclose deepfake image, audio, or video as artificially generated or manipulated.
A practical first step
Because scope is fact-specific, many US teams start by mapping which of their AI systems could be used by people in the EU, and which Article 50 paragraph each system might touch. Our free scope check gives an automated, informational indication to help frame that conversation with counsel — it is not a determination that the Act does or does not apply to you.
Common questions
Can the EU AI Act apply to a company with no EU office?
In general, yes — the Act is designed to reach certain providers and deployers outside the EU whose AI systems are placed on the EU market or whose outputs are used in the EU. Whether it reaches your business is fact-specific; confirm with qualified counsel.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.