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Guide

The EU AI Act in Spain: What Online Shops Must Disclose

AI Act

The EU Artificial Intelligence Act — Regulation (EU) 2024/1689 — applies directly in Spain as a Regulation. It entered into force on 1 August 2024 and applies in phases: prohibited AI practices from 2 February 2025, general-purpose AI model obligations from 2 August 2025, and most high-risk rules from 2 August 2026.

For a Spanish online shop, the practical focus is Article 50 — the transparency rules. This guide covers what a Spanish-facing shop should disclose, why Spanish-language disclosure matters, and Spain’s distinctive step of setting up a dedicated AI supervisor.

Shops are usually deployers

Most merchants use third-party AI — a chatbot, an image generator, a writing assistant. A shop that uses such a system in its business is generally a deployer. Deployers carry lighter duties than the providers who build the systems, but the Article 50 transparency rules apply to them directly.

The Article 50 duties

Disclose AI interactions

If customers interact with an AI chatbot or voice assistant, they must be told they are dealing with an AI system unless it is already obvious. A short notice at the start of the conversation normally suffices.

Label synthetic media

AI-generated or AI-manipulated images, audio and video should be marked as such, and deep fakes disclosed. Some AI-generated text published to inform the public is also in scope, though a routine product description is not the target.

  • Chatbots and voice assistants: state that it is AI.
  • AI-generated imagery: label it.
  • Deep fakes and synthetic audio or video: disclose clearly.

Disclosure in Spanish

Article 50 requires clear and distinguishable disclosure at the first interaction. Spanish consumer law expects information directed at Spanish consumers to be given in Spanish. A transparency notice only in English is unlikely to be enough for a Spanish-facing shop, and regional co-official languages may be relevant depending on where you sell.

Spain’s AI supervisor: AESIA

Spain moved early to create a dedicated body for AI oversight — the Spanish Agency for the Supervision of Artificial Intelligence, known as AESIA. This makes Spain relatively distinctive: rather than relying only on existing regulators, it established a purpose-built agency intended to play a central role in AI supervision. Even so, the precise mapping of AI Act market-surveillance functions across Spanish authorities was still being settled through 2025-2026, so treat the fine detail as qualitative and check the current position.

Checklist for a Spanish shop

  • Map where AI meets the customer across your storefront.
  • Add a clear Spanish notice for any customer-facing chatbot.
  • Label AI-generated images and synthetic media.
  • Record which tools are AI and who supplies them.

For the wider framework, see our overview of the EU AI Act and the complete AI Act guide.

This article is educational, not legal advice.