In this article
The AI Act Article 50 transparency obligations apply to covered systems from August 2, 2026. People must be told when they interact directly with an AI system, including a customer-facing assistant. Official source.
A practical check
Show the disclosure at the point of conversation, review automated answers, and provide a human handoff. Distinguish the system provider’s role from the business deploying it.
A support widget automatically answers 'where is my order?' The visitor should understand that it is AI before sharing information; a human path should remain for cases the tool cannot resolve.
What the evidence supports
A generic label does not replace checking obligations for the specific use. Public-interest text and manipulated audiovisual content raise other transparency cases. Date the check and retain the source documentation so that later changes can be verified.
Who is speaking to the customer?
When a user interacts with an AI system rather than a person, disclosure should be clear at the relevant point of interaction, subject to the exceptions in the law. A sentence hidden in general terms does not necessarily solve that practical problem. Transparency about AI and personal data duties are separate checks.
Audit the assistant in use
Open the chat as a new visitor on phone and desktop. Check what is disclosed before or at the start of the exchange, how to reach a person, and what the assistant does when it does not know an answer. Test a pricing question, a complaint, and a question containing personal information. Capture the screens and record the version of the wording shown so the real journey can be demonstrated.
Clarify responsibilities
The provider of a system and the business deploying it may have different obligations. Identify who configures disclosure, validates answers, and handles errors. The Commission's FAQ helps interpret Article 50, but applying it to a particular use requires checking the application date, each actor's role, and the actual interaction. A single banner should not be presented as a complete compliance solution.
Questions for the vendor
Where does disclosure appear? Ask for a screenshot of the real journey before the assistant's first response, not just a sentence in sales documentation.
What can the tool handle? Test limits around prices, complaints, and sensitive requests; provide a route to a person.
Who keeps evidence? The business deploying the tool should retain the disclosure wording, launch date, and configuration changes. For an uncertain legal case, review the full journey and each actor's role.
