The EU AI Act in Germany: What Online Shops Must Disclose
AI ActThe EU Artificial Intelligence Act — Regulation (EU) 2024/1689 — is a Regulation, not a Directive. That means it applies directly in Germany without needing a German transposition statute. It entered into force on 1 August 2024 and applies in phases: prohibited AI practices from 2 February 2025, obligations for general-purpose AI models from 2 August 2025, and most high-risk rules from 2 August 2026.
For the typical German online shop, the part that matters most is Article 50, the transparency rules. This guide explains what a shop operating in Germany should be disclosing, why the language of disclosure matters, and how the national enforcement picture is still taking shape.
Why the AI Act reaches ordinary shops
Most merchants are not building AI systems. They buy them: a chatbot from a SaaS vendor, an image tool that generates product photos, a copywriting assistant. In the language of the AI Act, a shop that uses such a system in the course of its business is usually a deployer. Deployers carry a lighter load than providers, but Article 50 still places transparency duties directly on them.
The Article 50 transparency duties
1. Tell people when they are talking to a machine
If your shop uses an AI chatbot or voice assistant that interacts with customers, people must be told they are dealing with an AI system — unless that is already obvious to a reasonably observant person. In practice a short, clear line at the start of the chat is enough.
2. Label AI-generated media
Where you publish AI-generated or AI-manipulated images, audio or video, that content should be marked as artificially generated or manipulated. Deep fakes — realistic media that could be mistaken for a real person or event — must be disclosed. Certain AI-generated text intended to inform the public on matters of public interest also falls within scope, though a routine product description is a different case.
- Chatbots and voice bots: disclose the AI interaction.
- AI product or lifestyle imagery: mark it as AI-generated.
- Synthetic audio or video, including deep fakes: disclose clearly.
Disclosure in German
The AI Act requires disclosures to be clear and distinguishable, at the latest at the point of the first interaction. Separately, German consumer and marketing law expects information aimed at German consumers to be understandable to them, which in practice means German. A transparency notice buried only in English is unlikely to satisfy either the spirit of Article 50 or existing German consumer-information expectations.
Who enforces it in Germany?
Here the honest answer is qualitative. The AI Act requires every Member State to designate national competent authorities, including market-surveillance authorities. In Germany the detailed allocation across federal and Länder bodies — and any implementing legislation to accompany the Regulation — was still being settled through 2025 and into 2026. Germany already has strong candidates in its data-protection and product-safety supervisory structures, but you should treat the precise designation as a moving target and check the current position rather than rely on a fixed name.
A practical checklist for a German shop
- List every place AI touches the customer: chat, imagery, generated copy.
- Add a plain German notice wherever a chatbot speaks to customers.
- Label AI-generated visuals and any synthetic media.
- Keep a short internal note of which tools are AI and who supplies them.
For the wider framework, see our overview of the EU AI Act, the complete AI Act guide, and our Germany country page.
This article is educational, not legal advice.