Do I need to disclose AI in customer service (chat, email, voice)?

Chat and voice: yes, clearly — Article 50(1) covers direct AI interaction. Fully automated AI email replies: best practice and arguably covered when conversational; AI-drafted human-sent replies: no, a human is the interactor. When in doubt, disclose.

By channel

ChannelDisclosure needed?
Website chatbotYes, always, first contact
Voice AI on phone linesYes, at call start
Fully automated AI email agentGrey zone leaning yes — if it converses with a person, treat it as covered
AI-drafted, human-sent repliesNo — the human interacted, not the AI
Internal AI tools staff useNo (not public interaction)

Why "when in doubt, disclose" wins

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