Guides · Article 50 · EU AI Act
AI chatbot disclosure requirements (EU AI Act)
If your business runs an AI chatbot, virtual assistant, or similar system that talks to customers, Article 50(1) of the EU AI Act is the paragraph to understand. This guide explains what it says, grounded in the regulation text. It is informational only and not legal advice.
What Article 50(1) requires
The regulation text provides that providers must ensure that AI systems intended to interact directly with natural persons are designed and developed so that the people concerned are informed that they are interacting with an AI system — unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use (Article 50(1), Regulation (EU) 2024/1689).
In everyday terms: if people might reasonably think they are talking to a human, the system should let them know it is AI.
The 'obvious' exception
The obligation does not apply where the AI nature is obvious to that reasonably well-informed, observant and circumspect person given the context. Whether your interface clears that bar is fact-specific — a clearly labeled 'AI assistant' widget is different from a lifelike agent presented as a person. If you intend to rely on the exception, it is worth documenting your reasoning.
How and when to disclose
Article 50(5) says the information must be given in a clear and distinguishable manner, at the latest at the time of the first interaction, and meet applicable accessibility requirements. Teams commonly place the notice in the opening message and as a persistent label on the widget.
- Identify each AI system that interacts directly with people.
- Draft the AI-interaction disclosure wording shown to users.
- Confirm it appears at or before the first interaction.
- Record how it meets applicable accessibility requirements.
- If relying on the 'obvious' exception, document why.
Common questions
What should an AI chatbot disclosure say?
A short, clear notice that the user is interacting with an AI system, shown at or before the first interaction — for example, an opening line stating the assistant is automated AI, not a human agent, with an option to reach a person. See our guide to writing an AI disclosure statement for examples. This is illustrative, not legal advice.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.