For marketplaces, Article 50 splits cleanly along one line: who is using the AI?
Content your sellers create with AI and upload (AI-generated product photos, AI-written listings) is, under the AI Act's framework, the sellers' affair. The deployer of an AI system is whoever uses it under their own authority, and a platform merely hosting third-party content doesn't thereby become the deployer of the AI that made it. The Article 50(4) labelling duties for a realistic AI image in a listing sit with the seller who published it there.
Your platform's own AI features are the mirror image. A shopping assistant chatbot under your marketplace's brand, an AI feature that generates listing copy or product imagery for sellers, an AI-powered support bot: for those, you're the provider, and the corresponding duties (chatbot disclosure under 50(1); machine-readable marking of generated output under 50(2)) are yours. Note the second one especially. A "generate your listing with AI" button makes you the provider of a generative system, with marking and detection obligations most marketplaces haven't yet inventoried.
Between the two poles there are honest gray areas. For instance, a platform that automatically AI-enhances every uploaded product photo is no longer merely hosting. The practical test: if your systems transform or generate content, analyse it as your AI use; if they merely store and display what sellers made elsewhere, it's the sellers'.
Separate laws can still reach the hosting side (DSA duties, consumer-protection rules on misleading imagery), so "not our Article 50 duty" is not the same as "not our problem." Many marketplaces are choosing to require AI-labelling in their seller policies: a contractual layer the Act doesn't mandate but doesn't forbid.
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