Guides · Article 50 · EU AI Act
AI disclosure in mobile apps
Small screens, onboarding flows, and platform accessibility settings make AI disclosure a distinct design problem on mobile. This guide covers considerations grounded in Article 50(5) of the EU AI Act. It is informational only, not legal advice, and the examples are illustrative, not approved wording.
As on the web, a disclosure surface is not the obligation itself. Which Article 50 paragraph applies depends on the AI system in the app, and whether any applies is fact-specific.
Translating Article 50(5) to mobile
Article 50(5) provides that the information must be given in a clear and distinguishable manner, at the latest at the time of the first interaction or exposure, and must conform to applicable accessibility requirements. On mobile, teams often read that as:
- Surfacing the notice within the flow — for a chat feature, in the first message rather than only in a settings screen the user may never open.
- Making it distinguishable on a small screen without relying on hover states that do not exist on touch.
- Supporting platform accessibility features such as dynamic type, screen readers (VoiceOver, TalkBack), and sufficient contrast.
- Keeping the disclosure available if the user returns later, not only during a one-time onboarding step.
Mobile-specific pitfalls to check
Common issues teams look for include disclosures placed in an app-store description rather than in the running app, notices that are dismissed automatically before they can be read, and text rendered inside an image so assistive tools cannot reach it. Because layouts differ across devices, teams often verify the disclosure on real screen sizes and with accessibility settings enabled.
Illustrative in-app copy (not approved wording)
Tone and placement only — adapt with qualified counsel:
- First-message line: 'You're chatting with an AI assistant, not a person.'
- Generated-content label: 'Created with AI.'
Common questions
Is putting the AI notice in the app store listing enough?
Article 50(5) points toward giving the information in a clear and distinguishable manner at the latest at first interaction or exposure and meeting accessibility requirements — which typically points to the running app, where the person actually encounters the AI, rather than only a store listing. Whether your approach suffices is fact-specific; confirm with qualified counsel.
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.