The European Union’s AI Act marks a milestone in the regulation of Artificial Intelligence. Starting in 2025, binding rules for the development and application of AI will apply for the first time. For solo self-employed individuals who work with AI systems, urgent questions arise: What obligations will freelancers face? Does the law also apply to small providers? And how can they prepare now?
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Definition: What is the AI Act?
The Artificial Intelligence Act (AI Act) is an EU regulation that introduces uniform rules for the use of Artificial Intelligence across the European Union. Adopted in 2024, the regulation will be phased in starting in 2025. Its goal is to ensure safety, transparency, and the protection of fundamental rights when using AI systems – without stifling innovation.
The four risk levels of the AI Act
The AI Act is based on a risk-oriented approach and classifies AI systems into four categories:
- Unacceptable risk: Certain AI applications are banned outright because they violate EU values. This includes systems that manipulate human behavior or exploit vulnerabilities – such as social scoring or predictive policing.
- High risk: These systems are allowed but subject to strict regulations. This category includes AI in critical infrastructure, law enforcement, or HR processes. Even participation in projects involving these applications can place freelancers under high-risk obligations.
- Limited risk: AI that interacts with users, like chatbots or content-generating tools, must meet transparency and labeling obligations.
- Minimal risk: Systems such as spam filters or video games are lightly regulated or exempt.
Who is affected by the AI Act?
The AI Act applies to developers, providers, and users of AI systems – regardless of company size. Whether a system is subject to stricter requirements depends on its area of application and the associated risk. Freelancers and small agencies are affected if they:
- Develop or train AI applications
- Offer AI-based services like chatbots or content generated using ChatGPT
- Use tools like GPT-4 or Midjourney to create content
The law distinguishes between internal use and commercial offerings. If you offer AI-based products or services to clients, stricter rules apply.
Key requirements for freelancers under the AI Act
Freelancers who develop AI systems or offer them as service providers will soon have to meet certain legal requirements. These obligations depend on the risk category assigned to the specific project. The regulations are particularly relevant for applications with limited or high risk. However, even for lower-risk systems, minimum standards still apply.
1. Transparency obligation
If a tool or service uses AI, users must be clearly informed. This applies particularly to chatbots and generative AI tools. The user must know that they are interacting with an AI system and not with a real person.
2. Labeling obligation
AI-generated content must be labeled as such, depending on the context. For example, if a text, image, or video is created using Artificial Intelligence, it may be necessary – depending on the context – to label the content as AI-generated. The goal is to prevent deception and help users properly interpret the nature of the content.
3. Documentation requirement
Freelancers developing AI applications must document their systems in a technically comprehensible way. Required information includes model training, data sources, algorithms, and intended use. This is especially important for high-risk applications and must be made available to regulatory authorities upon request.
4. Duty of data diligence
Another important aspect is the requirement for data quality. AI systems cannot be trained with arbitrary datasets. The AI Act mandates that training data must be representative, as error-free as possible, and free from discrimination. Freelancers involved in development must ensure their datasets meet these criteria.
5. Conformity marking
In some cases, the AI technology used must also be registered or provided with what is known as a conformity marking. This primarily affects applications embedded in products – such as hardware solutions that require CE marking under the AI Act. While this is rarely relevant for most digital projects, it should not be overlooked in larger client projects.
These requirements should not be underestimated, especially for solo self-employed professionals and small service providers. Complying with the regulations requires not only technical understanding but also legal expertise. If necessary, freelancers may need to collaborate with specialists to properly assess risks and meet documentation standards.
AI Act timeline: Key dates for freelancers
| Deadline | What applies from then on? |
|---|---|
| July 2024 | Publication of the AI Act in the Official Journal of the EU |
| August 2024 | Law enters into force; 24-month transition period begins |
| February 2025 | Ban on AI systems with unacceptable risk |
| August 2025 | Rules apply to providers of general-purpose AI models; market oversight begins |
| August 2026 | Full application of the AI Act |
| August 2027 | Transitional rules for high-risk AI systems in products become mandatory |
The EU AI Act was published in the Official Journal in July 2024 and officially entered into force on August 1, 2024. A transition period has been in place since then, during which the new rules are being gradually phased in.
Since February 2025, certain AI systems classified as posing an unacceptable risk have been banned. Starting in August 2025, additional requirements will apply – for example, for providers of general-purpose AI models and for the implementation of supervisory structures.
By August 2026, all provisions of the AI Act will be fully applicable. For AI systems integrated into physical products, special transitional arrangements apply, extending the deadline until August 2027.
Opportunities through the AI Act
The AI Act brings not only new obligations but also new chances for freelancers.
A significant opportunity lies in the growing demand for consulting on AI compliance. Small and medium-sized enterprises in particular need external support to implement AI projects in accordance with the law. Freelancers with the right expertise can play a key role here, and they can position themselves, for example, as:
- AI compliance consultants for SMEs
- Specialists in ethical AI development
- Project managers overseeing compliant AI implementation
Standardized rules will also help professionalize the AI market. Freelancers who stay informed and prepare early will have a clear competitive advantage.
Challenges freelancers may face
At the same time, the new legal regulation brings challenges, such as:
- Legal complexity: Categorizing AI technologies into risk levels is not always clear-cut and can lead to uncertainty, especially in projects involving hybrid applications.
- Industry-specific rules: In addition, there are industry-specific regulations – such as in healthcare or HR – that may impose additional requirements and must also be taken into account.
- Client hesitation: Clients may become more hesitant to initiate AI projects in the future, particularly if they are unsure about the legal requirements. If complying with the AI Act seems too demanding, companies may postpone such projects. This highlights once again that freelancers’ qualifications and specialization can be a decisive factor in project acquisition.
In the long run, the AI Act could help strengthen trust in AI systems. As a result, there may be increasing demand for compliant AI development – opening new doors for freelancers with the right expertise.
How freelancers can prepare
According to the Freelancer Study 2025, 77% of freelancers already use AI tools. While the law will be fully enforceable by August 2026, preparing early is essential to avoid disruption or liability.
1. Assess your services
Freelancers should first assess their own services in light of the AI Act’s risk categories. Do the AI systems they use or offer fall into the high-risk group? This primarily concerns software that makes automated decisions about applications, credit approvals, or access to public services. The use of AI in these areas is subject to particularly strict requirements.
2. Ensure transparency
Even for less regulated applications – such as AI-generated texts or images – freelancers should already prioritize transparency. In the future, content created with the help of AI will need to be clearly labeled. Solo self-employed individuals should therefore make it standard practice to include appropriate notices in their project descriptions or product details.
3. Clarify contractual responsibilities
Discuss AI-related obligations with clients early in the project. Clear contractual agreements can prevent disputes and clarify who is responsible for compliance.
4. Stay informed and up-to-date
For freelancers, it is definitely worthwhile to pursue further training in AI-specific law and technical standards. Online seminars on the AI Act help keep your knowledge up to date. In addition, tools and platforms that assist with risk assessment or documentation are set to become increasingly important. Freelancers can benefit from using these digital tools to streamline their processes and work more efficiently.
Outlook: What changes to expect in 2025?
From February 2025, bans on high-risk systems come into effect. By August 2025, additional rules for general-purpose AI models and oversight mechanisms begin. Freelancers working with generative AI must already comply with transparency and labeling obligations.
High-risk systems will face more detailed technical, legal, and documentation requirements. The European AI Office will coordinate implementation, with national authorities handling enforcement.
As the regulation evolves, additional guidelines and sector-specific rules will emerge. Freelancers should regularly review updates and remain proactive in adapting their work practices.
FAQ – Frequently Asked Questions about the AI Act for freelancers
When does the AI Act apply to freelancers?
It comes into effect in phases starting in 2025. Transparency obligations start early, while high-risk systems have transition periods of up to 36 months.
Does the AI Act apply to freelancers or just large companies?
Yes, it applies to all developers and users of AI systems, regardless of company size. Freelancers are included if they develop or commercially use AI.
What obligations apply when using GPT-4, Midjourney, or similar tools?
If you generate and publish or sell AI content, you may need to meet transparency and labeling obligations. Use is allowed but subject to specific rules.
What are the consequences of violating the AI Act?
Violations can result in fines of up to €35 million or 7% of global turnover. Proportional penalties apply to smaller providers. High-risk or banned applications are treated most seriously.
How can I prepare now?
Review your projects for risk level, start labeling AI-generated content, and clarify responsibilities with clients. Invest in training and consider legal consultation if needed.
By proactively engaging with the new requirements, freelancers can position themselves not just for compliance – but for long-term success in the evolving AI landscape.
The AI act is a good thing, AI needs regulations.
Absolutely, regulations are crucial to ensure that AI is developed and used responsibly. It’s important to strike a balance between innovation and ethical considerations, so we can harness AI’s potential while minimizing risks.