Guides · Article 50 · EU AI Act
Chatbot disclosure before 2 August 2026: what to say and where
Of the four Article 50 duties that apply from 2 August 2026, the chatbot disclosure in Article 50(1) is the one most businesses meet first — anyone running an AI assistant that talks to customers is potentially in its territory. The good news: for many products this is one of the fastest duties to implement, because it is mostly wording and placement.
This update distils what the regulation text asks for and shows illustrative wording. Whether 50(1) applies to your bot is fact-specific — confirm with qualified counsel.
The requirement in one paragraph
Article 50(1) provides that providers must ensure AI systems intended to interact directly with people are designed and developed so that the people concerned are informed they are interacting with an AI system — unless that is obvious to a reasonably well-informed, observant and circumspect person given the circumstances and context of use. Article 50(5) adds that the information must be clear and distinguishable, given at the latest at the first interaction, and meet applicable accessibility requirements.
What tends to pass the bar — and what does not
Reading those two paragraphs together, the pattern teams converge on is a plain notice at the very start of the conversation plus a persistent cue on the widget. Approaches that bury the fact — a line deep in the terms of service, a faint footer, a label that flashes once — sit uneasily with the clear-and-distinguishable and first-interaction language. Illustrative wording only, to adapt with counsel:
- Opening line: 'You're chatting with an AI assistant, not a human. Ask for a person any time.'
- Widget label: 'AI assistant' in the header, visible throughout the conversation.
- Hand-off: 'I'll connect you with a member of our team now.'
The 'obvious' exception, honestly handled
The duty does not apply where the AI nature is already obvious to that reasonably well-informed, observant and circumspect person in context. Some products genuinely clear the bar; many are closer than they think to a lifelike agent a customer could mistake for a person. If you intend to rely on the exception rather than disclose, the disciplined move is to write down why — and have counsel pressure-test the reasoning before August. Our free scope check gives an informational read on whether 50(1) is likely in play for your bot.
Common questions
Where exactly should the AI notice appear?
Article 50(5) points to the information being given in a clear and distinguishable manner at the latest at the first interaction, and meeting accessibility requirements. Teams commonly put it in the opening message and keep a persistent label on the widget. How that lands in your product is fact-specific — verify with qualified counsel.
Sources
Drafted with AI assistance against the EUR-Lex Article 50 text; edited and fact-checked by Matthew Anglim.
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