Article 50 Chatbot Disclosure: What Your AI Must Tell Users by August 2

What happened

Article 50(1) of the EU AI Act requires that providers of AI systems intended to interact directly with natural persons must design the system so that individuals are informed they are interacting with AI. The obligation applies from August 2, 2026.

This is not about high-risk AI classification. A simple customer service chatbot that poses no safety risk still needs to comply if it interacts with users.

What it means for your business

Every AI-powered interaction point needs to be audited and updated:

• Customer service chatbots: Must display a clear notice before or at the point of interaction — not in a footer or help page
• Virtual assistants: Voice-based AI must audibly identify itself as AI
• AI phone systems: Automated calls using AI must disclose the AI nature at the start of the call
• Email drafting AI: If an AI system drafts or sends emails on behalf of a person, the recipient should be informed

The requirement is for the disclosure to be "clear and timely." Regulators will likely interpret this as: visible before the user makes any decision based on the interaction.

What to do now

1. Inventory all AI interaction points. List every place where AI communicates with customers, employees, or partners
2. Design disclosure messages. Keep them short and clear: "You are chatting with an AI assistant" or "This call is handled by AI"
3. Place disclosure prominently. At the start of the conversation, not after. In the chat window header, not in small print
4. Test user comprehension. Can a reasonable person understand they are talking to AI? If not, redesign
5. Document the implementation. Record what disclosure was added, where, when, and the rationale for the placement

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements change frequently — verify current rules with official sources. Published June 17, 2026 by Sawai Gyoseishoshi Office, Hiroshima, Japan.