Article 50 transparency obligations for chatbots, voice assistants, and conversational AI. Deadline: 2 August 2026.
Note: If your chatbot interacts with users, it must clearly disclose that it is an AI system. This is a limited risk obligation under Article 50 — no full compliance documentation is needed, just transparency. Penalty for non-compliance: up to €15M or 3% of turnover.
What chatbot operators must do
Disclose that users are interacting with an AI system (Article 50(1))
Make the disclosure before or at the start of the interaction
Use clear, understandable language — not buried in T&Cs
If your chatbot generates content, mark it as AI-generated (Article 50(2))
Ensure AI literacy for staff operating the chatbot (Article 4)
Compliant disclosure examples
✅ "You're chatting with an AI assistant. A human agent is available if needed."
✅ "This is an automated AI response. Type 'human' for a real agent."
✅ "Powered by AI. Responses are generated automatically."
❌ "Terms of service apply. See section 14.3 for AI disclosure." (not clear enough)
When a chatbot becomes HIGH-RISK
A standard customer support chatbot is limited risk. But it escalates to high-risk if it also:
Makes or assists employment/HR decisions (Annex III, category 4)
Performs credit assessment or insurance pricing (Annex III, category 5)
Determines eligibility for public benefits (Annex III, category 5)
Performs biometric identification (Annex III, category 1)
Recognises emotions in workplace/school settings (prohibited — Art. 5)
FREE TOOL
Generate your Article 50 disclosure notice
Fill in your details. Get ready-to-paste disclosure text for your chatbot. No signup required.
3 variants generated — choose the one that fits your interface. All are compliant with Article 50(1) of Regulation (EU) 2024/1689.
Short — for chat bubble or header
Standard — for first message or footer
Formal — for Terms of Service / Privacy Policy
Need this in French, German, Spanish, Italian, Dutch or Polish?
The Chatbot Compliance Pack includes all 7 language variants + implementation guide + T&C clause + machine-readable marking guide (Article 50(2)).
Article 50(1) applies to any AI system "designed to directly interact with natural persons." This includes:
Customer support chatbots (website, app, messaging platforms)
Sales and lead qualification bots
Voice assistants and IVR systems
AI-powered email response systems
Internal employee helpdesk bots
What about ChatGPT, Copilot, and similar tools?
If you integrate a third-party LLM (ChatGPT, Claude, Gemini) into your product or workflow, you are a deployer. The transparency obligation applies to you — you must disclose to your users that they're interacting with AI, even if the underlying model is from a third party.
Compliance checklist for chatbot operators
Requirement
Article
Deadline
Effort
Add AI disclosure to chatbot interface
Art. 50(1)
2 Aug 2026
1 hour
Review and update Terms of Service
Art. 50(1)
2 Aug 2026
2-4 hours
Mark AI-generated content as detectable
Art. 50(2)
2 Aug 2026
1-2 days
Train staff on AI literacy
Art. 4
Already in effect
1-2 days
Document compliance measures
General
Ongoing
Half day
Penalties
Non-compliance with Article 50 transparency obligations carries fines of up to €15 million or 3% of worldwide annual turnover. For SMEs, fines are proportionally reduced to the lower of the fixed amount or the percentage.