No. Article 50's transparency duties contain no small-company carve-out: no headcount threshold, no revenue floor, no "micro-enterprise exemption" of the kind some EU rules have. A two-person startup whose AI chatbot talks to EU users owes the same disclosure as a bank's. Where the Act acknowledges company size is in consequences and support, not in the duties themselves.
The consequence side is genuinely different for you, and worth stating precisely because headline coverage gets it wrong. The standard penalty ceiling for transparency violations is up to €15M or 3% of worldwide turnover, whichever is higher. But for SMEs and start-ups, Article 99(6) flips it to whichever is lower. For a small company, 3% of turnover is the operative ceiling, and actual fines are discretionary, weighed against the Act's listed factors, with corrective orders the realistic first step in early enforcement. A ceiling is not a forecast.
On the technical duties, one anti-hope note: the Article 50(2) marking duty's "as far as technically feasible" standard is judged objectively. The draft guidelines are explicit that a small provider's limited resources don't lower the bar. If you provide a generative system, being three engineers doesn't shrink the marking duty; what shrinks it is the honest technical state of the art, documented.
The proportionate reading for most startups is still cheerful, because most startup duty profiles are small: a branded chatbot needs a sentence and a badge; realistic AI media needs a label; ordinary AI-assisted marketing copy needs nothing. The full compliance surface for a typical seed-stage SaaS is an afternoon, and the evidence trail is a folder of dated screenshots.
One startup-specific angle worth taking seriously: enterprise procurement. Due-diligence questionnaires are already asking about AI Act posture, and "here's our disclosure, our labelling rule, and our evidence log" closes that question in one email. For a startup, Article 50 compliance is less about fine avoidance than about not losing a deal to a checkbox.
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