Article 50: The Obligation That Affects Every Chatbot
Article 50 of Regulation (EU) 2024/1689 — the EU AI Act — establishes a clear and direct obligation: every AI system that interacts with people must identify itself as such. There are no exceptions based on company size, industry, or technology type.
Art. 50 — Transparency obligations
Multa: hasta 15M EUR or 3% of global annual turnover
This means that if your company operates a chatbot — whether for customer service, sales, technical support, or any other function — that chatbot must inform the user that they are interacting with artificial intelligence, not a human.
Why Art. 50 Is Different from the Rest of the EU AI Act
While most EU AI Act obligations apply only to high-risk systems (Annex III), Article 50 applies to all AI systems that interact with people. This includes:
- Customer service chatbots
- Virtual sales assistants
- Technical support bots
- Automated FAQ chatbots
- Any conversational AI system
It doesn't matter if your chatbot is built on GPT-4, Claude, Gemini, Llama, or a proprietary model. If it interacts with users in the EU, it must comply.
5 Steps to Art. 50 Compliance
1. Audit Your Current Chatbot
Before making changes, you need to know where you stand. A transparency audit checks three key points:
- Pre-interaction: A visible notice exists before the user initiates the conversation
- First interaction: The chatbot identifies itself as AI in its first message
- Responses: Responses include indicators that they come from an AI
2. Implement Pre-Interaction Disclosure
Add a visible notice next to the chatbot widget that clearly indicates it is an artificial intelligence assistant. Effective examples:
- "AI-powered virtual assistant"
- "Chatbot powered by artificial intelligence"
- "You're chatting with an AI assistant"
3. Configure the Welcome Message
The chatbot's first message should explicitly identify itself as AI:
"Hi, I'm an AI-powered virtual assistant. How can I help you?"
4. Add Response Indicators
Include periodic reminders that responses come from an AI, especially when the chatbot provides sensitive information or recommendations.
5. Document Your Compliance
Maintain documented evidence of your transparency measures. This is essential to demonstrate compliance in case of inspection.
Fines for Non-Compliance
Non-compliance with Article 50 can result in fines of up to 15 million euros or 3% of global annual turnover, whichever is greater.
The Deadline Is Approaching
Article 50 transparency obligations become fully enforceable from August 2026. National supervisory authorities will have sanctioning power from that date.
Don't wait until the last moment. Transparency changes are relatively simple to implement, but they require auditing, implementation, and documentation.