Guides · Article 50 · EU AI Act
AI bots on WhatsApp and Messenger under Article 50
Businesses increasingly run AI assistants inside messaging apps like WhatsApp and Messenger for support, orders, and bookings. Two Article 50 paragraphs can bear on those bots: 50(1), the provider-side duty to inform people they are interacting with an AI system, and — if the bot generates content — 50(2), the provider-side marking of synthetic text. This guide explains both from the regulation text. It is informational only, not legal advice, and does not name any platform or tool as in or out of scope.
The interaction disclosure — Article 50(1)
Article 50(1) provides that providers must ensure AI systems intended to interact directly with people are designed so those people are informed they are interacting with an AI system, unless this is obvious to a reasonably well-informed, observant and circumspect person given the context. Messaging is a context where a human agent is often expected, so whether the AI nature is 'obvious' can be a live question. A business that builds or configures its own bot may be acting provider-side for that system, while the messaging platform plays its own role — which is why mapping who is provider and who is deployer matters before deciding what applies. Whether the interface clears the 'obvious' bar is fact-specific.
If the bot generates text — Article 50(2)
Where a messaging bot generates synthetic text, Article 50(2) can also come into view. That paragraph asks the provider of the system to mark such outputs in a machine-readable format as artificially generated or manipulated, subject to carve-outs — including where the system performs an assistive function for standard editing or does not substantially alter the input. Whether a support bot's generated replies fall inside 50(2), and whether a carve-out applies, are fact-specific questions. Article 50(5) then points toward a clear, distinguishable disclosure at or before the first interaction, meeting accessibility requirements — often placed in the opening message.
Common questions
Does my WhatsApp support bot need to say it's AI?
Article 50(1) points the provider of the bot toward informing people they are interacting with an AI system, unless that is already obvious in the messaging context. Whether that applies to your specific bot, and who counts as the provider, are fact-specific — verify with qualified counsel. Our free scope check gives an informational starting point.
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.