Open-Source LLM Compliance (Llama, Mistral, Self-Hosted)
Obligations for deployers hosting open-weight models on private cloud infrastructure.
1. Do Open-Source Models Fall Under Article 50?
Yes. While open-weight models enjoy certain research exemptions under Article 2(12), deployers who integrate self-hosted open-weight LLMs (such as Llama 3 or Mistral 7B) into public-facing web applications remain fully subject to Article 50 transparency obligations. Deep Legal Context: Hosting open-source LLMs like Llama 3 or Mistral on private infrastructure does not exempt an organization from Article 50. While the models themselves may have research exemptions, the moment they are deployed in a public-facing application, the deployer assumes responsibility for compliance. This requires setting up robust client-side wrappers that enforce disclosure rules, regardless of the underlying infrastructure. Self-hosted setups must be audited just as rigorously as managed SaaS solutions.
2. Self-Hosted Infrastructure Audit Checklist
Deployers hosting open-source models on AWS, GCP, or private servers must ensure client-side web wrappers enforce chatbot greeting disclaimers and output copy schema tags.
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