Retail

A Swiss retailer that also sells into the EU is under two legal systems at once. Switzerland has no AI law of its own, and the FDPIC confirmed on 8 May 2025 that existing data protection law applies directly to AI.¹ For a retail assistant that handles customer data, the revised FADP is the rule that matters most.

Two problems are renewing budgets:

• Answering customers on the channel they already use, at a cost per conversation that finance can see. Our multi-channel concierge is in production on web, Telegram, Messenger, Instagram and WhatsApp, with cost estimated per channel.
• Testing an assistant against the ways a customer will try to break it: pressure, euphemism and a question framed to sound harmless. Our adversarial evaluation harness is an internal build with 117 cases and a 100% merge gate, written for allergen questions in hospitality. The method carries over.

Two back-office builds sit behind these, both working prototypes. The back-office agents handle invoices with duplicate and fraud checks. The tiered document pipeline handles supplier contracts under per-tenant budget caps.

Start with channel consolidation: it is measurable within weeks, and a wrong answer is a redirected conversation, not a wrong credit decision.

FADP Art. 21 applies to retail more often than teams expect. A customer subject to a significant automated decision may be told about it, state their view and ask for review by a person. A declined instalment application or an algorithmically set price can be such a decision. Exceptions apply where the decision is needed for a contract the customer requested or the customer consented.² Design the human review path in from the start.

AI Act Annex III point 5(b) classifies AI that evaluates the creditworthiness of natural persons, or sets their credit score, as high-risk. It names no buy-now-pay-later product as such, but an instalment checkout that scores a shopper’s credit can still fall under it. Point 5(c) covers AI for risk assessment and pricing in life and health insurance, if you sell it. These obligations apply from 2 December 2027.³

Article 27 of the Digital Services Act requires an online platform that uses recommender systems to explain the main ranking parameters in plain language. Where more than one ranking option exists, it must offer one not based on profiling. If you run a marketplace with ranked listings, check whether this applies.⁴

This page is a screening note, not legal advice. Ask your counsel before relying on a classification.

Start with the AI opportunity assessment. In one to two weeks it names the metric and the owner, and its regulatory applicability note checks your checkout and pricing tools against the rules above. If you already have a named metric for a concierge, a proof of value sprint is the next step. See also AI regulation in Switzerland.

• WorkAgent orchestration for the back office
• WorkAn adversarial evaluation harness for allergen safety
• WorkA multi-channel AI concierge, in production
• WorkA tiered document intelligence pipeline