Does our own logo on the chatbot make us the provider?
In short: If you embed the chatbot unchanged: no. The disclosure duty in Art. 50(1) falls on the provider of the system, not on you as the deployer. That is not our reading — the German regulator, the Bundesnetzagentur, states it expressly in its guideline on the transparency obligations: the duty „gilt für Anbieter von KI-Systemen, die direkt mit Menschen interagieren“. If you offer it under your own name or trade mark, it becomes unclear. Art. 3(3) defines a provider as someone who places on the market or puts into service an AI system „under its own name or trademark“. A logo, your own product name, an assistant that looks like something you built — where exactly that tips is unresolved. And we will not tell you. We know of no page that resolves it cleanly, and we think it dishonest to assert a line here that does not exist.
What is settled
Art. 50(1) addresses the provider. That is not a reading we invented: the German regulator, the Bundesnetzagentur, writes in its guideline on the transparency obligations that the duty „gilt für Anbieter von KI-Systemen, die direkt mit Menschen interagieren“, naming chatbots expressly as an example. Embed a finished chatbot and run it as delivered, and you are a deployer under Art. 3(4) — you do not owe that notice yourself.
The other direction is equally settled: you may not remove the notice. Switching off the provider's disclosure interferes with the very duty that relieves you of it.
What is not settled
Art. 3(3) also makes a provider of whoever places on the market or puts into service an AI system „under its own name or trademark“. Many mid-sized companies do exactly that without calling it that: the assistant is not named “Vendor XY” but carries the company name, an icon of its own, a voice of its own.
At what point that turns a deployer into a provider is unresolved. We reviewed the German sources. One calls it “the exceptional case” and refers the reader to a lawyer. Another writes that one can “grow into the provider role”. The regulator's guideline does not address branding at all. None draws a line — and that is not an oversight, it is the honest state of the question.
Why we will not decide it for you
We could write a clean “no, a logo is not enough”. It would read well and it would be the dangerous direction of error: it would tell you that you owe nothing while your branding may have made you the provider, with the duties that attach.
There is also a disclosure to make about ourselves. The normative index from which KI Akte derives its classifications carries Art. 25 — the conversion mechanism — at low confidence; until 4 September 2026 it was missing entirely. Art. 50(1) is recorded there as not conclusively verified. We would rather say so than paper over it: on this point our own basis is weaker than the sentence would have to be.
What you can do instead
Three things that do not depend on the open question. First: leave the provider's notice in place. Second: record contractually who discharges the transparency duty — that is the question your vendor contract should answer anyway. Third: make the decision about the name the assistant appears under deliberately, and record it with a date. If someone asks in two years, that is the difference between a memory and evidence.
Frequently asked questions
We embedded a vendor's chatbot and changed nothing. Must we display the AI notice?
Under Art. 50(1) the duty falls on the provider of the system. The German regulator names chatbots expressly as an example and addresses the duty to providers. In practice: check that your provider supplies the notice — and do not remove it.
We put our logo on it and called it “Mia”. Does that change anything?
Possibly. Art. 3(3) makes a provider of whoever puts a system into service “under its own name or trademark”. Whether a name and a logo suffice is not conclusively settled. We know of no reliable source that draws the line, so we do not draw one either.
Why not just say?
Because a clean “no” here would be wrong in the dangerous direction: it would tell you that you owe nothing while your branding may have made you the provider. Our own normative index carries Art. 25 — the conversion mechanism — at low confidence, and Art. 50(1) as not conclusively verified. We write that down rather than paper over it.
So what can we do?
Three things that do not depend on the open question: leave the provider's notice in place; record contractually who discharges the transparency duty; and record, dated, the deliberate decision about the name the assistant appears under. If the question is asked later, that is the difference between a memory and evidence.
Does Art. 50 reach us anywhere at all?
As a deployer yes, but only via paragraphs 3 and 4: emotion recognition and biometric categorisation, deep fakes, and published AI text on matters of public interest. Paragraphs 1 and 2 address the provider.
Sources: Verordnung (EU) 2024/1689 (KI-VO), Art. 3 Nr. 3, Art. 3 Nr. 4, Art. 25, Art. 50 Abs. 1, Art. 50 Abs. 3, Art. 50 Abs. 4, Art. 113, Verordnung (EU) 2026/1744 (Digital Omnibus), Bundesnetzagentur, Leitlinie zu den Transparenzpflichten (Art. 50 KI-VO)
Primary sources: Regulation (EU) 2024/1689 on EUR-Lex · Digital Omnibus, Regulation (EU) 2026/1744 · Bundesnetzagentur — the German AI-Act authority