Does using free AI tools like ChatGPT create duties?
Yes, some. Free or paid doesn't change your role.
Drafted with AI help and checked against the official EU text before publishing.
Yes, some. Free or paid doesn't change your role. Using ChatGPT in your business makes you a deployer: helping your staff understand the AI they use (Article 4) has applied since 2 February 2025. The duty to tell people they are talking to an AI (Article 50(1)) sits with the company that makes the chatbot, from 2 August 2026.
Article 4 literacy has applied to that use since 2 February 2025. From 2 August 2026, people who talk to a bot on your site must be able to tell it is AI. If you only use ChatGPT internally to draft, the customer-facing mark is about what you publish, not about your private draft window.
This is general information, not legal advice.
What the law actually says
"Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use."— EU AI Act, Article 50(1) (Regulation (EU) 2024/1689); applies from 2 August 2026 · eur-lex.europa.eu
In plain words
- The provider of ChatGPT is the company that puts the model on the market. Your business, using it under your authority, is typically the deployer (Article 3(4)).
- Article 4 literacy still applies to that use, and it has applied since 2 February 2025.
- If a chatbot on your site talks to customers, check that it tells them it is AI — the maker has to build that in. If you built the bot yourself and offer it under your own name, you may count as its provider, and that duty would be yours. If you only use ChatGPT internally to draft, the customer-facing mark is about what you publish, not about your private draft window.
- A free plan does not switch the Act off. The test is how the system is used, not the price.
- Will look for signs of AI use in the folders you choose, and write them down for you.
- Will write a plain-language readiness report. No evidence reads "Not assessed", never a green tick.
- Will run as a free Windows program on your own computer and send nothing from it.
- Coming with Guard: a check every month, kept so you can see your history and what changed since the last one.
- Coming with Guard: a printable readiness pack built from your check results — AI use found, training notes, disclosure checklist.
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Readiness guidance, not legal advice. The Free Toolkit sends nothing from your computer.