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EU AI Act Article 50: what chatbot owners actually have to do by August 2

Updated June 11, 2026

If your website has an AI chatbot and people in the EU can use it, one specific duty lands on August 2, 2026: the people talking to it must be told they are talking to an AI system. That is Article 50(1) of the EU AI Act, and unlike most of the Act, it applies to ordinary businesses running ordinary chatbots.

Who it covers

The duty sits on whoever provides an AI system that is "intended to interact directly with natural persons." In practice: if you put a chatbot in front of customers, this is about you. It does not matter where your company is based. The AI Act applies based on where your users are, so a US or UK company with EU visitors is in scope.

There is one exemption: you do not need the notice if it is already "obvious to a reasonably well-informed, observant and circumspect person" that they are talking to AI. That sounds comforting, but it is a judgment call you would have to defend after the fact. A robot avatar is probably obvious. A chat window named "Sarah" that types like a person is probably not. Most deployments sit uncomfortably in between, which is why the safe move is to show the notice.

What a proper disclosure looks like

The Act does not prescribe exact wording, but the pattern regulators expect has two layers:

• A notice at or before the first interaction. The person should know they are talking to AI before they invest in the conversation, not after.
• On the chat surface itself. A line in your terms of service or a help page does not inform anyone at the moment of interaction.

Two details that get missed: the notice should be in a language the visitor understands (an English-only banner does not inform a French user), and it should appear on every surface where the chatbot is reachable, not just the homepage.

The part everyone forgets: proof

Article 50 compliance is cheap to claim and hard to prove. If a regulator or a complaining user asks whether your disclosure was actually shown in March, a screenshot taken in September proves nothing. The deployments that take this seriously keep a dated log of every disclosure render, tied to the exact wording and configuration that was live at the time.

What the fines look like

Breaches of Article 50 carry administrative fines of up to EUR 15 million or 3% of worldwide annual turnover, whichever is higher. Those are ceilings, not floors, and SMEs get the lower of the two amounts. Enforcement sits with national authorities in each member state. Nobody knows how aggressive year one will be, but the cost of being on the right side of this is a script tag and a few minutes, which is why waiting to find out is a strange bet.

The short version

1. Add a visible AI notice to every chatbot surface, shown at or before the first message.
2. Serve it in your visitors' languages.
3. Keep dated records that it was shown.
4. Re-check whenever you change the bot or where it runs.

Disclosed provides compliance tooling and records; this document is not legal advice. Review it with your counsel before relying on it.