With the implementation of the EU AI Act in 2024, companies working with artificial intelligence, automation, and data collection within the European Union are faced with new stringent requirements. The regulation affects not only AI system developers but also marketers, arbitrage specialists, SMM experts, and e-commerce businesses that use automation for data collection, ad targeting, or competitor monitoring.
In this article, we examine the specific requirements introduced by the EU AI Act, how they impact your work with proxies, and what technical measures can help avoid fines of up to ā¬35 million or 7% of the company's annual turnover.
What is the EU AI Act and who does it affect
The EU AI Act is the world's first comprehensive regulation on the use of artificial intelligence, adopted by the European Union in March 2024. The law will be implemented in phases: the first requirements will take effect from August 2024, with full implementation expected by 2026.
The regulation categorizes AI systems into four risk categories ā from minimal to unacceptable. But what is important for businesses is that the law affects not only companies developing AI models but also anyone using automated systems to collect and process data from European users.
Who is affected by the EU AI Act:
- Marketers and arbitrage specialists using AI for targeting in Facebook Ads, TikTok Ads, Google Ads
- E-commerce businesses scraping competitor data on marketplaces (Amazon, eBay, European platforms)
- SMM agencies automating work with accounts of European clients
- Companies using AI chatbots, recommendation systems, or automated user behavior analysis
- Any business collecting data on European users through automated tools
It is important to understand: even if your company is outside the EU, if you work with data from European users or provide services within the European Union, you are required to comply with the EU AI Act. This is similar to how GDPR operates.
Key requirements for data collection and anonymity
The EU AI Act introduces several critically important requirements for companies using automation and AI tools. Let's look at those that are directly related to the use of proxies and data collection.
1. Transparency in data collection
Companies are required to disclose what data they collect and how they use it. If you scrape data from European websites or social media for training AI models or market analysis, you must have a documented procedure for processing that data.
Practical example: if you scrape competitor prices on Amazon.de or monitor brand mentions on European social networks, you must document what data you collect, how long you store it, and for what purposes you use it.
2. Data minimization
The law requires collecting the minimum necessary amount of personal data. If anonymized data is sufficient for your task ā you are not allowed to collect identifiable information.
Here, proxies play a critical role: using residential proxies with IP rotation allows you to collect data without linking it to specific users, which complies with the principle of minimization.
3. Protection against discriminatory profiling
The EU AI Act prohibits the use of AI systems for discriminatory profiling of users based on race, ethnicity, political beliefs, or other sensitive characteristics. This affects ad targeting and automated decision-making systems.
For arbitrage specialists, this means: if you are testing ad creatives on a European audience through Facebook Ads or TikTok Ads, you must document that your AI algorithms do not use discriminatory targeting criteria.
4. Logging and auditing automated actions
Companies are required to maintain detailed logs of all automated actions related to data collection and processing. Logs must be kept for at least 6 months and be available for auditing by regulators.
This means: every request through a proxy, every scraping session, every automated action in an anti-detect browser (Dolphin Anty, AdsPower, Multilogin) must be logged with the time, IP address, type of data, and purpose of collection.
| EU AI Act Requirement | How it affects proxy usage | Penalty for violation |
|---|---|---|
| Transparency in data collection | Document all data sources and proxy IP addresses | Up to ā¬15 million or 3% of turnover |
| Data minimization | Use IP rotation for anonymization | Up to ā¬15 million or 3% of turnover |
| Ban on discrimination | Do not use proxy geolocation for discriminatory targeting | Up to ā¬35 million or 7% of turnover |
| Logging actions | Store logs of all requests through proxies for at least 6 months | Up to ā¬15 million or 3% of turnover |
How proxies help comply with the EU AI Act
A properly configured proxy infrastructure becomes not just a tool for bypassing blocks, but a critically important element of compliance with European regulations. Let's explore specific mechanisms by which proxies help meet the requirements of the EU AI Act.
Anonymization of data collection
Using proxies with automatic IP rotation allows you to collect data without linking it to specific user sessions. This is critically important for complying with the principle of data minimization.
Practical example: you are scraping product reviews on European marketplaces for sentiment analysis. By using residential proxies that rotate every 10 minutes, you collect public data without creating profiles of specific users ā this complies with the requirements of the EU AI Act.
Geographical segmentation to comply with local requirements
The EU AI Act requires compliance with different levels of data protection depending on the country. For example, Germany and France have additional national requirements for data processing.
Proxies allow you to set up separate data processing by country: German data is collected through German IPs with enhanced encryption and logging, while French data is collected through French proxies in compliance with local data storage requirements.
Controlling request frequency to prevent aggressive data collection
The EU AI Act classifies aggressive mass data collection as a high-risk activity requiring special permissions. Using proxies with customizable delays between requests allows you to demonstrate that your data collection is conducted in a "human" mode rather than through aggressive bots.
Example of compliant scraping setup:
- Rotation of residential proxies every 5-10 minutes
- Delay between requests of 2-5 seconds (simulating human behavior)
- Logging each request with a timestamp and purpose of collection
- Using User-Agent of real browsers of European users
- Limiting the number of requests: no more than 100-200 per hour from one IP
Separating production and testing environments
The EU AI Act requires separate testing of AI systems on synthetic data before using real user data. Proxies allow you to create isolated environments: a testing environment (using data center proxies for quick testing) and a production environment (using residential proxies for working with real European data).
Practical scenarios: marketing, scraping, advertising
Let's consider specific business scenarios where compliance with the EU AI Act is critically important, and how proper proxy setup helps avoid penalties.
Scenario 1: Traffic arbitrage on Facebook Ads and TikTok Ads
Arbitrage specialists often test ad creatives on a European audience using multiple accounts and automation. The EU AI Act classifies automated ad targeting as a high-risk AI system requiring strict compliance.
Regulatory requirements:
- Document all targeting criteria and prove the absence of discriminatory parameters
- Store logs of all advertising campaigns for at least 6 months
- Ensure transparency in the use of AI for bid and creative optimization
How to set up proxies for compliance:
- Use mobile proxies from European operators (Vodafone DE, Orange FR) for each advertising account
- Set up logging in an anti-detect browser (Dolphin Anty, AdsPower): record IP address, session time, targeting parameters
- Use sticky sessions (fixed IP for 10-30 minutes) for account stability, but with mandatory rotation between sessions
- Store backup logs on servers within the EU (GDPR and EU AI Act requirement)
Scenario 2: Scraping marketplace data for price monitoring
E-commerce businesses actively scrape competitor prices on Amazon, eBay, and European marketplaces. The EU AI Act requires minimizing the collection of personal data and transparency in automated processes.
Practical setup:
- Scrape only public data (prices, product names, ratings) without collecting personal information about sellers
- Use residential proxies with geographical ties to the country of the marketplace (German IPs for Amazon.de, French for Cdiscount.fr)
- Set delays between requests of 3-7 seconds to simulate human behavior
- Document the purpose of scraping in logs: "monitoring market prices for pricing own products"
Scenario 3: SMM automation for European clients
SMM agencies managing accounts of European clients on Instagram, TikTok, LinkedIn must comply with requirements for automated posting and audience interaction.
Critical points:
- The EU AI Act requires disclosure if content is generated by AI (e.g., AI-written posts or comments)
- Automated likes and comments may be classified as behavior manipulation, which is prohibited
- It is necessary to document client consent for automation and keep logs of all automated actions
Proxy setup:
- Each client account ā a separate residential proxy from the client's country
- Use sticky sessions lasting 24 hours for account stability
- Limit automation: no more than 50 actions per hour (likes, comments, follows)
- Maintain detailed logs: action time, action type, IP address, client consent for automation
Which type of proxy to choose for regulatory compliance
The choice of proxy type directly affects your ability to comply with the requirements of the EU AI Act. Different tasks require different types of proxies in terms of compliance.
| Proxy Type | When to Use | Compliance Benefits | Limitations |
|---|---|---|---|
| Residential Proxies | Scraping marketplaces, working with social media, advertising accounts | Real IPs of home users, high trust score, natural behavior | Higher cost, variable speed |
| Mobile Proxies | Facebook Ads, TikTok Ads, Instagram, multi-accounting | IPs from mobile operators, maximum trust, rare blocks | Most expensive, limited geography |
| Data Center Proxies | Testing, development, low-risk public data collection | High speed, low cost, suitable for testing environments | Easily detected, not suitable for high-risk tasks |
Recommendations for choosing for different tasks
For arbitrage and advertising (Facebook Ads, TikTok Ads, Google Ads):
Use mobile proxies from European operators. The EU AI Act requires maximum transparency in advertising systems, and mobile IPs provide the highest level of trust on platforms. One mobile proxy per advertising account, sticky session for 24 hours, mandatory logging of all sessions.
For scraping marketplaces and price monitoring:
Residential proxies with rotation every 10-15 minutes. This ensures anonymization of data collection (the EU AI Act requirement for data minimization) and reduces the risk of blocks. Be sure to use proxies from the same country as the target marketplace.
For SMM automation (Instagram, TikTok, LinkedIn):
Residential or mobile proxies with long sticky sessions (12-24 hours). The EU AI Act requires documentation of user consent for automation, so stability of IP is critically important to prevent security alerts for clients.
For developing and testing AI systems:
Data center proxies for testing environments, residential for production. The EU AI Act requires separate testing on synthetic data, so use fast data center proxies for dev/test, and residential only for working with real European data.
Technical setup: logging and data protection
The EU AI Act requires not only the correct choice of proxies but also a proper technical setup of the infrastructure for logging and data protection. Let's consider specific technical requirements.
Mandatory logging elements
Each request through a proxy must be logged with the following mandatory fields:
- Timestamp: exact time of the request with milliseconds (ISO 8601 format)
- Proxy IP address: which specific IP was used
- Proxy geolocation: country, city (to prove compliance with local requirements)
- Target URL: which resource was requested
- Purpose of data collection: brief description of the business purpose ("monitoring competitor prices", "testing ad creative")
- User ID/Session ID: session identifier for tracing
- Type of collected data: data category (public prices, ad metrics, public posts)
Setting up logging in anti-detect browsers
Most anti-detect browsers (Dolphin Anty, AdsPower, Multilogin, GoLogin) have built-in logging features, but they need to be properly configured to comply with the EU AI Act.
Setup in Dolphin Anty:
- Open Settings ā Logs ā enable "Extended logging"
- Set up automatic log export to cloud storage (AWS S3, Google Cloud Storage) with servers in the EU
- Set retention period of at least 6 months (EU AI Act requirement)
- Enable logging of all proxy connections with IP and geolocation
- Add custom fields for the purpose of data collection and type of data
Setup in AdsPower:
- Go to Team Settings ā Audit Log ā activate "Full audit trail"
- Set up a webhook to send logs to your monitoring system (Datadog, Splunk, ELK)
- Enable logging of proxy changes ā each IP change must be recorded
- Set up alerts when request limits are exceeded (protection against aggressive scraping)
Log storage: location and encryption requirements
The EU AI Act, in conjunction with GDPR, requires storing logs containing data of European users on servers within the European Union. This is critically important for compliance.
Important: If you use cloud storage (AWS, Google Cloud, Azure), ensure that the chosen region is within the EU: eu-west-1 (Ireland), eu-central-1 (Frankfurt), europe-west1 (Belgium). Storing logs on servers in the USA or Asia is a violation of the EU AI Act, with a fine of up to ā¬15 million.
Encryption requirements:
- Logs must be encrypted at rest (AES-256) and in transit (TLS 1.3)
- Access to logs only through authenticated APIs with two-factor authentication
- Regular access audits: who, when, and why requested the logs
- Automatic deletion of logs older than the retention period (usually 6-12 months)
Setting up proxy rotation for compliance
Proper proxy rotation is a key element in complying with the principle of data minimization. Different tasks require different rotation strategies.
| Task | Rotation Strategy | Compliance Justification |
|---|---|---|
| Scraping public data | Rotation every 5-10 minutes | Prevents data from being linked to specific sessions |
| Advertising accounts | Sticky session for 24 hours, then rotation | Account stability + logging of each IP change |
| SMM automation | Sticky session for 12-24 hours | Minimizes security alerts for clients |
| Monitoring competitor prices | Rotation every 10-15 minutes | Anonymization + protection against rate limiting |
Risks of non-compliance and penalties
The EU AI Act imposes some of the harshest penalties in the history of European regulation ā up to ā¬35 million or 7% of the company's global annual turnover (the larger amount is taken). It is important to understand the specific risks for your business.
Categories of violations and penalties
| Type of Violation | Example | Maximum Penalty |
|---|---|---|
| Use of prohibited AI systems | Discriminatory profiling in advertising | ā¬35 million or 7% of turnover |
| Non-compliance with requirements for high-risk systems | Lack of logging for automated targeting | ā¬15 million or 3% of turnover |
| Providing false information to regulators | Hiding facts of aggressive data collection | ā¬15 million or 3% of turnover |
| Violation of transparency requirements | Failure to disclose the use of AI for content generation | ā¬7.5 million or 1.5% of turnover |
Real case penalty forecasts (2024-2025)
Although the EU AI Act is just coming into force, typical penalty cases can be predicted based on GDPR experience:
Case 1: An arbitrage team with 50 Facebook Ads accounts
Violation: using AI for automated targeting without documenting criteria and logging. Aggressive data collection from European users to train AI models for bid optimization.
Projected penalty: ā¬500,000 - ā¬2,000,000 (for small businesses) or up to ā¬15 million for large arbitrage agencies.
Case 2: An e-commerce company scraping Amazon and eBay
Violation: mass scraping of seller data (including personal information) without complying with the data minimization principle. Storing logs on servers outside the EU.
Projected penalty: ā¬1,000,000 - ā¬5,000,000 depending on the volume of data collected.
Case 3: An SMM agency automating Instagram
Violation: using AI bots for automatic comments and likes without disclosing automation. Lack of client consent for the use of AI.
Projected penalty: ā¬250,000 - ā¬1,000,000 + a ban on working with European clients.
How to minimize risks
Compliance checklist for working with proxies and AI:
- ā Use residential or mobile proxies for working with European data
- ā Set up complete logging of all requests through proxies with mandatory fields
- ā Store logs on servers within the EU for at least 6 months
- ā Document the purpose of data collection for each session
- ā Set up IP rotation for anonymization (5-15 minutes for scraping)
- ā Limit request frequency (no more than 100-200 per hour from one IP)
- ā Collect only public data, minimize personal information
- ā Disclose the use of AI (if generating content or automating targeting)
- ā Obtain written consent from clients for automation (for SMM agencies)
- ā Conduct regular compliance audits (quarterly)
Conclusion
The EU AI Act has radically changed the rules for companies working with automation, AI, and data collection in the European market. Proxies are no longer just a tool for bypassing blocks ā they are now a critically important element of compliance infrastructure that can protect your business from fines in the millions of euros.
Key takeaways: use residential or mobile proxies for working with European data, set up complete logging of all sessions, store logs on servers within the EU, document the purpose of data collection, and comply with the principle of minimizing personal information. Proper IP rotation setup, limiting request frequency, and choosing the right type of proxy for each task are not just technical details, but mandatory requirements for compliance with the EU AI Act.
If you are working with the European market ā arbitraging traffic on Facebook Ads and TikTok Ads, scraping marketplaces, automating SMM, or using AI for data analysis ā investing in a compliance-ready proxy infrastructure will pay off by protecting you from fines and preserving your business reputation. We recommend starting with residential proxies from European providers with built-in logging and geographical segmentation ā they provide the optimal balance between functionality and compliance with EU regulations.