Article 50 transparency and GPAI model obligations are enforceable now. Fines reach €15 million or 3% of worldwide annual turnover, whichever is higher. The law applies to anyone who puts their name on an AI system that talks to people or generates content — not just the big model labs.
€15M is a rounding error for one company, an extinction event for another. That asymmetry is what ThinkNEO corrects.
Two questions. If both are yes, Article 50 obligations apply to you today.
Do you sell to or serve customers in the EU?
Two separate outputs. First: does the law apply to you, and how. Second: what operational controls you’re missing.
No email required for the result.
Chatbots, voice assistants, in-app AI agents — including a branded support bot you built on top of someone else’s model.
ThinkNEO applies the disclosure rule at runtime, on every in-scope request. Not a note in your docs — a policy the control plane enforces before the model answers.
Any image, audio, or video generated or substantially manipulated by AI, unless a substantive human editorial layer intervenes.
ThinkNEO embeds C2PA-compatible markers and keeps a registry entry per artifact. Detection stays functional even after re-encoding.
Content depicting real people in situations that didn’t happen — unless part of clearly artistic, satirical, or public-interest work with disclosure.
ThinkNEO detects deepfake generation attempts, requires an editorial-review flag, and refuses if it’s absent.
Systems that infer emotion, feelings, or characteristics from faces, voices, or biometrics must inform affected people (Article 50). In workplace or education contexts, these uses are PROHIBITED entirely under Article 5, since 2 Feb 2025.
ThinkNEO gates biometric-inference calls with a disclosure requirement and refuses uses that fall under Article 5’s prohibited list.
If you operate in an Annex III area (employment decisions, credit scoring, education, critical infrastructure, migration, essential services), full high-risk obligations (Article 6, Annex IV technical documentation, human oversight evidence, risk monitoring, post-market surveillance) become enforceable in 2027-2028. ThinkNEO stores the evidence you’ll need — we don’t fake the certification today.
ThinkNEO is a tool for deployers — the companies using AI systems, not the model labs that build them. Where an article primarily binds the provider, we cite the corresponding deployer duty (mostly Art. 26) so you can see which obligations you inherit and which you’d need from the model provider. The requirements are real and the work is real; below is what building each control yourself looks like versus what ThinkNEO ships out of the box.
| EU AI Act need | Without ThinkNEO | With ThinkNEO |
|---|---|---|
Immutable audit trail Article Art. 12 (provider) · Art. 26(6) (deployer) | Custom append-only logs per provider. Manual verification. | Hash-chained audit ledger. One line per event. Verify anytime. |
Per-request logging Article Art. 12 (provider) · Art. 26(6) (deployer) | Provider SDK logs, disparate formats, no cross-provider view. | Unified request log, all providers, one schema. |
Access control Article Art. 26 | Manual IAM, per-tenant custom code, drift on rotation. | Per-key policies, per-user scopes, rotate without downtime. |
Policy enforcement Article Art. 50 | Middleware you maintain. Provider-specific. Bypassed by any new endpoint. | Runtime policies enforced before the model answers. New providers inherit the policy set. |
Cost accountability Article — (business practice, supports Art. 26) | Provider bill reconciliation. Manual tagging. Weekly finance reviews. | Per-system, per-team spend in real time. Alerts before overrun. |
Runtime governance Article Art. 26 · Art. 50 (deployer duties) | Documented process. Reviewed at audit time. | Enforced at request time. Evidence generated automatically. |
AI system inventory Article Art. 26 (deployer duties) | Spreadsheets. Out of date within weeks. | Auto-registry: one entry per system, owner + purpose. Updates on first use. |
We don’t ship these as “live” today. We store the evidence you’ll need.
Article 14 (provider design) · Article 26(2) (deployer implementation) — evidence that a natural person reviewed or could intervene. We log the reviewer and the decision.
Article 9 (provider) · Article 26(5) (deployer) — ongoing risk management and intended-purpose monitoring. We log every enforcement event as candidate evidence.
Article 72 (provider post-market monitoring) · Article 26(5) (deployer intended-purpose monitoring) — plan required. Our audit ledger is the raw feed you’ll build the plan from.
Every paid tier ships the same product — full runtime enforcement, inline policy blocks, budget hard-stops, complete audit ledger. Higher tiers don’t unlock features. They give you more room. Monitor-mode observation is free forever.
Prices in USD, billed monthly via Stripe. Included-request allowances degrade to observe-only (never a hard cutoff); structural limits (tenants, users, projects, keys) block creation at the cap. No metered overage.
Yes if the output of your AI system is used in the EU, or if you offer it to EU users. Physical location of your company doesn’t matter — market location does.
If you put your name on the system (branded chatbot, in-app assistant, generated content published under your brand), yes. Using someone else’s model doesn’t make you a provider — but re-exposing it to end users under your name makes you a deployer with Article 50 duties.
€15 million or 3% of worldwide annual turnover, whichever is higher, for most Article 50 breaches. €35M or 7% for prohibited uses under Article 5. National authorities enforce; enforcement modalities are being finalized.
No. You need enforcement — the operational controls that prove you did what the law asks. That’s what we ship. Legal review comes when your Legal team drafts your public disclosure text or reviews your Annex-IV documentation.
A consultancy tells you what the law says. We give you the runtime plumbing that satisfies it — logs, marks, disclosures, enforcement points, evidence — from $19/mo, without a form.
You do not need a lawyer or a Big-Four consultant. You need the plumbing. That’s what we ship.
