BRUSSELS — In its response to the European Commission's stakeholder consultation on the draft Guidelines for transparency requirements under Article 50 of the AI Act, the Business Software Alliance (BSA) emphasized the need for greater clarity regarding the respective responsibilities of AI providers and deployers.

"The AI Act requires disclosures to be clear, distinguishable, and provided at the first interaction with users. As drafted, however, the Guidelines create uncertainty for technology providers whose platforms are deployed and customized by enterprise customers," said Hadrien Valembois, Director, Policy – EMEA, at BSA. "The final Guidelines should more clearly delineate provider and deployer responsibilities, particularly for configurable, multimodal, and agentic AI systems. Greater legal certainty will support effective compliance while enabling continued innovation and adoption of AI across Europe."

BSA has consistently advocated for clear allocation of responsibilities across the AI value chain as the EU AI Act moves from adoption to implementation. As AI systems become increasingly configurable and enterprise deployments involve multiple actors, it is essential that transparency obligations are assigned to the entities best positioned to control how systems are deployed and presented to users.

The full submission can be found here.