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AI chatbot disclosure: what Article 50 of the AI Act requires
Short answer
A person starting a conversation with a chatbot has to know they are dealing with AI, at the latest at the first interaction. The transparency obligations of Article 50 of the AI Act apply and are enforced from 2 August 2026. The notice has to be visible everywhere the chatbot opens, and a handover of the conversation to an employee has to be clear.
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Author: Syntalith · 3 min read
Statistics
The AI Act in customer service: statistics 2026
2 Aug 2026
from this date the European Commission enforces the transparency obligations of Article 50 of the AI Act, including telling people they are talking to AI. High-risk systems under Annex III follow from 2 December 2027.
2 August 2026
According to the European Commission (2026), the transparency obligations of Article 50 of the AI Act apply and are enforced from 2 August 2026, and providers of systems placed on the market earlier have until 2 December 2026 to mark content under Article 50(2).
2 December 2027
According to the European Commission (2026), the rules on high-risk systems in Annex III of the AI Act apply from 2 December 2027, and those on systems built into regulated products from 2 August 2028.
47%
According to the European Commission (2026), customer service is the most common use of AI among EU SMEs and mid-caps that already use it: 47%.
Source: European Commission, Flash Eurobarometer 578 (2026) ↗
52.5%
According to Eurostat (2025), 52.5% of EU enterprises that considered AI but did not use it named a lack of clarity about the legal consequences.
Figures checked: 22 October 2026
What Article 50 of the AI Act says exactly
Paragraph 1 of Article 50 of the AI Act concerns systems intended to interact directly with people: the provider designs them so that a person knows they are talking to AI, unless this is obvious from the circumstances. Paragraph 5 requires this information to be given in a clear and distinguishable way, at the latest at the first interaction. The European Commission states that the transparency obligations apply and are enforced from 2 August 2026. Whether a company is a provider or a deployer is for a lawyer to judge and depends on the specific solution.
What an AI chatbot disclosure can look like
A proposal for a simple company chat: „You are talking to an AI assistant. You can ask to be put in touch with our team”. Use the second sentence only if the handover to a person really works. First check what the user sees when the window opens: a notice that disappears after a second, sits outside the visible area or appears only in the terms of use does not do its job.
The home page shows an AI label, but the same plugin opens without a header in the complaints form. Checking only the home page will not catch that.
- New conversation: the notice is visible at the latest at the first interaction
- Small screen and screen reader: the text is accessible and does not cover the chat field
- Embedded on another page: the same notice and the same way to get in touch
- Handover to an employee: the message matches who is really replying
- Handover failure: an honest description of the situation and a working way to get in touch
A change of who is replying must be clear too
When an employee takes over the conversation, the interface shows the change. When an employee only approves an AI draft, the description of the service matches that role. Do not sign a model's answer with the name of an agent who did not write it.
- 01Openingthe AI notice is visible before the first answer
- 02Conversationanswers from approved sources
- 03Handovera message that an employee is taking over
- 04Employeesees the conversation history and does not start from scratch
Who is responsible for what
Lawyer
whether the company is a provider or a deployer, and which obligations follow
assessment
Product team
the wording of the notice, its place in the chat window, the handover message
design
Plugin supplier
visibility on every page and at every entry to the chat
implementation
The most common mistake is a disclosure made once, on the home page, and forgotten in later embeds. The second trap is a „connecting you to an agent” message when the handover works only in business hours. Outside them the chatbot should say plainly when the team will reply and leave a way to get in touch that really works. The third trap is model answers signed with a name that suggests a person.
The label does not settle the quality of the answers
An AI label does not confirm that the bot reads the terms correctly, processes data properly or grants the customer the right entitlements. Article 50(6) keeps the other obligations from other laws, including the GDPR and consumer law. Before a build, check what your current plugin can do: if it lets you fix the notice and the handover, you do not need a new app.
An AI Act and GDPR audit at Syntalith costs from €700 net and ends with a register of AI tools, a list of changes to settings and a training plan for the team. A review of the conversation, the sources of the answers and the handover points is also part of the AI process audit, from €600 net. For the free analysis, the address of the page with the chatbot and a description of when a person takes over the conversation are enough.
Worked example · Scenario
How we count the payback: an AI chatbot for your company
We run the same count for your website in the free analysis.
€2,327
a month for answering 1,000 customer questions
Payback: 1.5 mo.
4 minutes for an employee to answer a question and checking in 15% of the old time are our assumptions. €34.90 an hour is the EU average hourly labour cost for 2025 according to Eurostat, for companies with 10 or more employees. Model cost: Claude Sonnet 5.5, about 4,000 + 400 tokens per answer, at the ECB rate of 1.1205 USD per euro on 22 October 2026.
See the full calculation →
