TRACENOTICE · ARTICLE 50 IMPLEMENTATION GUIDE

AI voice-agent disclosure: put the notice in the call, not in a policy page.

For AI systems intended to interact directly with natural persons, Article 50(1) requires notice that the person is interacting with AI unless that fact is obvious from context. Article 50(5) requires clear and distinguishable information no later than the first interaction or exposure.

Engineering translation: for an AI phone agent, the disclosure should be part of the opening interaction itself. A website privacy notice does not replace a disclosure at the voice surface.

Voice deployment checklist

  1. Map every inbound and outbound call path using AI.
  2. Place the AI disclosure in the opening turn before substantive qualification or transaction steps.
  3. Keep wording short enough to work naturally in speech.
  4. Localise the notice for every supported call language.
  5. Make transfer to a human clear when the identity changes.
  6. Test voicemail, interrupted greetings, callback flows and warm transfers.
  7. Retain the prompt/config version, test recordings or transcripts where lawful, and release evidence.

Example operational wording

“Hi, you’re speaking with Acme’s AI assistant. I can help with booking and common questions.” Final wording should be reviewed in the context of the actual deployment and any sector-specific rules.

Primary sources

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

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