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fix: Article 50 end-user scope + Article 13 logs vs documentation distinction
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@ -122,11 +122,15 @@ Connect to a persistent backend (Langfuse, Helicone, or your own database). Set
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Article 13 requires providers of high-risk AI systems to supply deployers with sufficient information — instructions for use, accuracy metrics, known limitations — to operate the system appropriately. This is provider-to-deployer transparency.
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LiteLLM's contribution to Article 13:
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- **Model routing is logged** — deployers can see which model handled each request
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- **Cost attribution** — deployers know which features consume the most AI resources
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- **Fallback chains are visible** — when a primary model fails and a fallback serves the response, this is logged
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- **Provider documentation pass-through** — LiteLLM's docs link to each provider's model cards and usage policies
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Article 13 compliance requires the provider of the high-risk system to produce and maintain system-level documentation: intended purpose, accuracy and robustness metrics, known risks, and technical measures for monitoring. This is a documentation obligation, not a logging obligation.
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LiteLLM's observability features provide **supporting evidence** that can inform Article 13 documentation, but they do not satisfy Article 13 on their own:
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- **Model routing logs** — help compile which models are in use and how requests are distributed
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- **Cost attribution** — supports resource usage documentation
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- **Fallback chain visibility** — provides evidence of system behavior under failure conditions
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- **Provider documentation links** — LiteLLM links to upstream model cards, but these describe the LLM providers' models, not your high-risk AI system as a whole
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You must independently produce system documentation that covers how your specific deployment uses LiteLLM, its intended purpose, performance characteristics, and residual risks.
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## Article 50: End-user transparency
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@ -134,8 +138,7 @@ Article 50 requires deployers to inform end users that they are interacting with
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What you need to add:
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- User-facing disclosure that AI is involved in generating responses
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- Documentation of which models are active and their known limitations
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- Information about how routing decisions are made (cost, latency, quality)
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- A mechanism for users to identify when an AI-generated response has been delivered (e.g., clear labeling in the UI)
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Note: Article 50 applies to chatbots and systems interacting directly with natural persons. It has a separate scope from the "high-risk" designation under Annex III — it applies even to limited-risk systems.
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