TRACENOTICE · ARTICLE 50 IMPLEMENTATION GUIDE

AI chatbot disclosure: what product teams should actually ship.

Article 50(1) applies from 2 August 2026. For AI systems intended to interact directly with natural persons, people must be informed that they are interacting with AI unless that is obvious from context. Article 50(5) requires the information to be clear and distinguishable and provided no later than the first interaction or exposure.

Engineering translation: do not hide the primary disclosure in terms, privacy pages or a post-chat footer. Put it on the interaction surface before or at the first user interaction, and preserve evidence of the deployed state.

Implementation checklist

Identify every entry point: launcher, embedded chat, mobile modal, authenticated support view and SDK embed.
Use explicit wording such as “AI assistant” where the AI nature is not already obvious.
Place the disclosure before or at the first interaction.
Keep the AI identity reasonably persistent during the conversation.
Make human handoff visually distinguishable.
Test supported locales, mobile layouts, keyboard navigation and accessibility.
Capture versioned screenshots, release references and acceptance evidence.

What this checklist does not decide

Whether the AI nature is already “obvious” is context-dependent. Product teams should preserve the operational evidence and route legal interpretation to qualified counsel where necessary.

Primary sources

EU AI Act consolidated text — Article 50
European Commission Article 50 guidelines

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