Case 02: LLM Chatbot
LLM Chatbot: is it legal in the EU, the United States and China?
The system on trial: general-purpose customer service. The same product meets three legal realities. Each verdict below is an editorial summary of the instruments cited under it, so every claim can be checked against the official text in one click.
EU: TRANSPARENCY DUTY. US: LIGHT-TOUCH. CN: LICENSED: FILING REQUIRED
LLM Chatbot: how does the European Union treat it?
TRANSPARENCY DUTY. Say you're an AI. Art. 50(1) requires users to be told they're interacting with an AI system (unless obvious): from 2 Aug 2026. The underlying model provider separately carries GPAI duties, systemic-tier if above 10²⁵ FLOPs.
TRANSPARENCY DUTY means: Allowed, provided users are told AI is involved and content is labeled.
Source: Art. 50(1): AI Act: chatbot disclosure duty; Art. 53/55: AI Act: GPAI model duties
LLM Chatbot: how does the United States treat it?
LIGHT-TOUCH. A plain service bot faces no AI-specific law. Only FTC deception rules and state disclosure duties apply: California's SB 1001 bot law and Utah's on-request disclosure.
LIGHT-TOUCH means: No dedicated AI law, only general consumer/deception rules apply.
Source: FTC §5: FTC Act §5: deception rules; SB 243: California companion-chatbot law
The trapdoor
Companion chatbots are now specifically regulated (CA SB 243, NY) with a private right of action of at least $1,000/violation, and AI implying medical licensure is banned in California (AB 489).
LLM Chatbot: how does China treat it?
LICENSED: FILING REQUIRED. No filing number, no launch. Public-facing GenAI with 'public opinion attributes' needs a security assessment and CAC filing before launch; outputs are dual-labeled since 1 Sep 2025 and the filing number must be displayed. 868 services had filed by Apr 2026: this is why ChatGPT is unavailable in China.
LICENSED: FILING REQUIRED means: Must register with the state and pass review before launch.
Source: GenAI Measures Art. 17: CAC GenAI Interim Measures: pre-launch gate; S7: CAC GenAI filing registry
The other 5 cases on the board
- AI Hiring Tool: legal in the EU, the US and China?CV screening & candidate ranking. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: MOSTLY UNREGULATED.
- Medical Diagnostic AI: legal in the EU, the US and China?AI-driven diagnostic device. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: LICENSED: FILING REQUIRED.
- Deepfake Generator: legal in the EU, the US and China?synthetic media tool. EU: TRANSPARENCY DUTY. US: LIGHT-TOUCH. CN: HEAVILY REGULATED.
- Credit Scoring AI: legal in the EU, the US and China?automated creditworthiness. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: HEAVILY REGULATED.
- Police Live Facial Recognition: legal in the EU, the US and China?real-time biometric ID in public. EU: PROHIBITED. US: MOSTLY UNREGULATED. CN: HEAVILY REGULATED.
Read the regimes behind these verdicts
- The three regime dossiers explain why European Union, United States and China reach different answers about the same product.
- The Framework Explorer holds every instrument cited on this page, each with its own page, status, provisions and sources.
- Open this case on the interactive board to see the three stamps land side by side.
- The EU AI Act Explorer serves the text of Regulation (EU) 2024/1689 itself, one page per provision.
Knowing the verdict is step one. Passing the assessment is the job.
The programs teach the work that follows: classification calls, conformity assessment, filings, documentation, and the judgment to defend every decision.
VERIFIED 29 JUL 2026. The verdicts are editorial summaries of the instruments cited above, not rulings. Study aid, not legal advice: the official texts are always authoritative.