Companies outside the EU
Sell AI products into the EU
We build the record keeping, human approval and supplier file your clients in the EU ask for into your product, working in English.
What we build for you
An AI product you can sell and use in the EU, with your duties built in.
The controls EU law asks for, built into your product
A record of what it did, human approval, the AI notice and marked output.
A deployment in Europe for your clients in the EU
The part handling their data runs in a European region or with a European provider.
The supplier file your financial clients must ask for
One file from the real configuration: data location, subcontractors, retention, audit rights, exit.
A version that runs on your client's own premises
For clients whose data may not leave their building, with no internet connection.
These are examples of what we can build. They do not describe client work.
Which kind of deployment a client in the EU accepts depends on where its data may go. The three kinds of deployment are explained on the solutions page.
What we are, and what we are not
We build what EU law asks for into your product and work beside your own counsel; where the law asks for a representative in the EU, you appoint one yourself. The AI Guys is not a representative service.
How we work
The free briefing costs nothing. Each paid step has its own fixed price, in writing before it starts.
- 1. Free briefing
- 2. Discovery
- 3. Design
- 4. Build
- 5. Run and improve
Discovery can be done remotely.
How each step works, on the solutions page
You work with us in English, by video
We are in the Netherlands and work in writing and by video; calls for other time zones are arranged early or late in the day.
What EU law asks of you
It depends on whether you provide or deploy each system, and whether its output is used in the EU.
- If the GDPR reaches you, you appoint a representative in the EU in writing, a duty since 25 May 2018.
- Before a high-risk system or a general-purpose model enters the EU market, you appoint an authorised representative there; for models since 2 August 2025.
- Your financial clients in the EU must write terms on data location, incident help, audit rights and exit into your contract, since 17 January 2025.
- People must be told they are dealing with an AI system, and generated content must be marked, since 2 August 2026.
- The high-risk duties start on 2 December 2027 for uses such as credit scoring and hiring, and on 2 August 2028 for AI inside products.
The words of the law
“providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the Union”
“This Regulation applies to the processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or (b) the monitoring of their behaviour as far as their behaviour takes place within the Union.”
“Where Article 3(2) applies, the controller or the processor shall designate in writing a representative in the Union.”
“Prior to making their high-risk AI systems available on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union.”
“unrestricted rights of access, inspection and audit by the financial entity, or an appointed third party, and by the competent authority”
What you risk
The Dutch, Italian and Greek data protection authorities each fined Clearview AI, an American company with no establishment in Europe, under the GDPR.
Clearview AI, fined by the Dutch data protection authority in 2024
€30.5 million
Final
Source and caveat
On 3 September 2024 the Autoriteit Persoonsgegevens fined Clearview AI, an American facial recognition company with no establishment in Europe, €30.5 million.
General Data Protection Regulation (Regulation (EU) 2016/679).
Clearview AI did not object, so it can no longer appeal; further penalties of up to €5.1 million apply if the violations continue. No source we checked on 5 October 2026 shows that the fine was paid.
Source: Autoriteit Persoonsgegevens, news item of 3 September 2024 (English page), accessed 5 October 2026.
Worked examples
These are worked examples. They do not describe real clients.
- What a European bank's questionnaire asks of a software company in the United States
Written for the chief technology officer of a software company outside the EU.
- A British company, a marking tool and the long reach of Article 2
Written for the chief technology officer of an education technology company outside the EU.
- A New York legal technology company and the questionnaire from Amsterdam
Written for the chief executive and the chief technology officer of a legal technology supplier.
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