Disclose the summaries’ AI-generated nature to clients: Which approach addresses the specific client-facing
Client-facing disclosure addresses synthetic-content transparency; internal records and technical documentation remain separate high-risk controls.
The question
A financial institution in the European Union deploys an AI system whose high-risk obligations apply. It generates client-facing summaries from financial documents, and assume the EU AI Act’s synthetic-content transparency duty applies. Which approach addresses the specific client-facing constraint without confusing it with internal evidence duties?
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- Retain the generated summaries internally for audit purposes.Internal retention supports record-keeping, but does not communicate synthetic-content information to clients receiving the summaries.
- Disclose the summaries’ AI-generated nature to clients during delivery. ✓This directly addresses the assumed synthetic-content transparency duty while leaving separate high-risk documentation and monitoring duties intact.
- Publish the model’s full training documentation alongside every client summary.Technical documentation may support high-risk governance, but publishing complete training materials is not the stated client-transparency requirement.
- Add a general disclaimer to the vendor contract.A contract disclaimer may allocate responsibilities, but it does not itself provide the required client-facing disclosure.
The trap
Match the control to its audience: users need notices, while deployers and authorities need evidence. How to remember it
Client-facing disclosure addresses synthetic-content transparency; internal records and technical documentation remain separate high-risk controls.
How many of these would you get right?
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