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LIMITED RISK — Article 50 transparency required
Deadline: 2 August 2026. Article 50 has NOT been deferred by the Digital Omnibus. You need a disclosure on your Loom AI chatbot before this date. Fine for non-compliance: up to €15M or 3% of turnover.

Loom AI EU AI Act Compliance: What Teams Using Async Video Must Know

Loom lets teams record and share short videos with AI-powered transcripts, summaries, chapters, and filler-word removal. As Atlassian-owned Loom adds more AI features, the EU AI Act implications for business users are worth understanding clearly — most are minimal, but two specific scenarios require attention.

Minimal risk for most use: Loom AI used for internal async communication is minimal risk. AI-enhanced transcripts and summaries do not trigger Article 50(1) — no deceptive AI interaction. Article 50(2) may apply if AI-generated video scripts or AI-edited content is published externally at scale. GDPR applies to recordings of individuals.

What you need to do — step by step

  1. Assess your Loom use: internal async communication (minimal risk) vs. external customer-facing videos (higher Article 50(2) consideration)
  2. For AI-generated video scripts used in customer-facing content (sales videos, marketing, product demos): establish whether human review and substantial edit removes the labelling requirement for your team
  3. For Loom videos shared with EU clients or in EU marketing: if AI has generated the script with minimal human edit, add a brief AI disclosure in the video description or caption
  4. Ensure employees understand Loom AI transcripts may contain errors — do not rely on them as verbatim records for legally sensitive conversations
  5. Review data handling: Loom videos containing personal data (faces, voices, screen content with PII) should be covered by your GDPR data processing documentation
  6. Set a retention policy for Loom videos — automatic expiry for internal videos reduces GDPR data minimisation risk

Ready-to-use disclosure text for Loom AI

Copy one of these into your Loom AI bot's opening message:

This video was created with AI assistance (scripting and editing) and reviewed by [Name] before sharing.
AI-assisted video. Script generated with AI support, reviewed by our team.
Note: this video uses AI-generated captions and summary. Transcript may contain errors.

Need this in French, German, Spanish, Dutch, Polish, Italian?

The Chatbot Compliance Pack includes 7 language variants, a T&C clause template, a privacy policy AI section, and the Article 50(2) machine-readable marking guide.

Get Chatbot Compliance Pack — €49 →
Or use the free disclosure generator →

Loom AI and the EU AI Act: full analysis

What Loom's AI features actually do

Loom's AI suite includes automatic transcription, AI-generated video summaries and chapters, filler-word removal, AI title suggestions, and — more recently — AI script generation and AI-assisted video editing. The compliance picture differs significantly between these feature categories.

Passive AI features (transcription, summaries, chapters, filler-word removal) process a video a human has already recorded. These are assistive tools with no direct interaction with viewers and no consequential decisions about individuals' rights. EU AI Act risk: minimal.

Generative AI features (script generation, AI-drafted content for videos) create content that, if published without meaningful human review, edges toward Article 50(2) territory — particularly for customer-facing external communications.

Article 50(2): when does it apply to Loom videos?

Article 50(2) requires labelling of AI-generated content "intended to inform, entertain, or persuade natural persons." A Loom video where a human wrote the script, recorded themselves speaking, and used Loom AI only to improve the transcript and generate chapter markers is not AI-generated content — the human is clearly the author. A video where AI generated the full script, an AI avatar or heavily AI-edited recording delivers it, with minimal human creative input — this is closer to AI-generated content requiring disclosure.

For most business Loom users, the realistic question is: did a human meaningfully appear on camera and deliver the content? If yes, the AI assistance in editing and summarisation is invisible to viewers and does not trigger Article 50(2). The labelling obligation becomes relevant for fully AI-generated video content — a growing category as AI avatar tools become mainstream.

GDPR considerations for Loom in business

Loom videos often contain faces, voices, screen recordings with personal data, and conversations about individuals. GDPR applies. For internal videos, your privacy policy and employee data processing notices should mention video recording and AI processing. For external videos shared with clients or published publicly, ensure you have appropriate rights to all content shown and that any individuals appearing have consented to recording and distribution.

Loom's Atlassian ownership means EU data processing terms should be available — review your Loom data processing agreement, confirm EU data residency options, and add Loom to your sub-processor list if you handle personal data in Loom content.

Frequently asked questions

Does Loom AI require EU AI Act compliance?
For standard internal async communication, Loom AI is minimal EU AI Act risk. No Article 50(1) applies (Loom is not a chatbot interacting with users in real time). Article 50(2) may apply to externally published AI-generated video content with minimal human creative input. GDPR applies to any recordings containing personal data.
Do we need to label Loom videos as AI-generated?
Not for videos where a human recorded themselves and Loom AI only provided transcription, summaries, or editing assistance. Article 50(2) labelling is most clearly required when AI generates the full script and/or creates the video with minimal human creative authorship. Assess your specific workflow — most Loom business use does not require labelling.
Can we use Loom for recording client meetings and calls?
Yes, but GDPR applies. Clients must be informed before recording begins. Your DPA with Loom must cover processing of client-related personal data. Set retention policies so recordings are deleted when no longer needed, and ensure clients can request deletion of recordings that feature them.
Loom is now owned by Atlassian. Does this affect EU AI Act compliance?
Atlassian's ownership does not change your EU AI Act or GDPR obligations as a deployer. It does mean Loom should be covered by Atlassian's GDPR data processing infrastructure and DPA. Review the current Loom/Atlassian DPA to confirm EU data handling, and update your sub-processor list to reflect the Atlassian entity if you process personal data via Loom.