AI chatbot in customer service: the transparency duty (Art. 50)
Adopted 2026-06-16 · ≈ 2 min read · 
edited by Dirk Baaijen
If you use an AI chatbot for customer contact, Article 50 of the AI Act requires that the customer knows (or can reasonably know) they are talking to AI. No conformity assessment, but a clear disclosure.
Short answer: Anyone deploying an AI chatbot that communicates directly with customers must ensure the person concerned knows — or, given the circumstances, can reasonably know — that they are interacting with an AI system. That is the core of Article 50(1) of the AI Act. No conformity assessment or registration is required; what matters is a timely, clear disclosure.
What the obligation actually requires
Article 50(1) of Regulation (EU) 2024/1689 addresses the provider of an AI system intended to interact directly with natural persons. A customer-service chatbot is a textbook case. The provider must design and develop the system so that the persons concerned are informed that they are interacting with an AI system.
The Regulation provides one exception: disclosure is not required where this is obvious from the point of view of a reasonably well-informed, observant and circumspect person, taking the context into account. In addition, the duty does not apply to AI systems authorised by law to detect, prevent, investigate or prosecute criminal offences, subject to safeguards for the rights and freedoms of third parties — a situation that does not arise in ordinary customer service.
The information must be provided at the latest at the time of the first interaction. For a chatbot this means, in practice, a clear notice at the start of the conversation, not buried in terms and conditions.
How to handle this in practice
The standard is deliberately functional: the legal text prescribes no exact wording or design. A statement that the customer is speaking with an automated or AI assistant, placed at the start of the conversation, meets the thrust of the provision. What matters is that the disclosure is clear, distinguishable and aligned with applicable accessibility requirements.
Bear in mind that Article 50 is a transparency regime separate from the high-risk obligations. A customer-service chatbot is generally not a high-risk system, but the transparency duty still applies in full. If the chatbot also generates synthetic text, image or audio, additional marking obligations under Article 50 may come into play; these require a separate assessment.
When this starts to apply
The AI Act applies in phases. The transparency provisions of Article 50 fall under a later application phase than the prohibited practices. The exact date of application is subject to ongoing decision-making at EU level; for the current status, consult the official sources of the European Commission and the Official Journal. Organisations that give their customer-service chatbot a clear AI disclosure now are prepared in any case.
Read more: AI Act: timeline of obligations.
Take the scan.
Sources
- https://eur-lex.europa.eu/eli/reg/2024/1689/oj
Regulation (EU) 2024/1689 (AI Act), Article 50(1) (information duty for direct interaction with natural persons). - https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai
European Commission: overview page of the regulatory framework for AI (AI Act).
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