When your chatbot must say it is AI
Article 50(1) places the direct-interaction notice on providers of AI systems intended to interact directly with people. A site owner may also be the provider — for example when offering an own-brand assistant — but embedding a third-party tool does not automatically settle the role question.
Who this applies to
- Providers offering an AI chatbot or assistant directly to people in the EU
- Businesses offering an own-brand AI assistant for bookings, quotes or support
- Teams that materially modify or relabel a third-party AI system under their own name
- Non-EU providers whose system or output is placed or used in the EU
What the regulation requires
Article 50(1) of Regulation (EU) 2024/1689 requires providers to design direct-interaction AI systems so people are informed they are interacting with AI, unless that is obvious to a reasonably well-informed, observant and circumspect person. The information must be clear, distinguishable and accessible at the latest at first interaction. Article 99 sets a maximum fine of €15 million or 3% of worldwide annual turnover, subject to proportionality and the specific case.
Implementation steps
- 1Scan the rendered public website to record visible AI interactions, disclosure wording and exact source URLs.
- 2Confirm who is the provider, who is the deployer and whether an exception applies.
- 3Install the free one-script RapidAct badge and tailor the wording to the actual system.
- 4Verify the live desktop and mobile experience before the first interaction, then record the URL, wording, owner and verification date.
Common implementation gaps
- Assuming the website owner is always the provider — establish the contractual and product role.
- Hiding the notice in a settings page or terms document — it must be visible at first contact.
- Assuming a human-sounding bot name makes the AI interaction obvious.
- Believing the 2027 high-risk-system delay also moves Article 50's transparency date.
The assessment
Company assessment
€99
One payment per company.
Get a specialist-reviewed AI inventory, system classifications, required notices and a prioritised action plan within 24–48h.
What you receive
- •AI inventory and system classifications
- •Article 50 duties by touchpoint
- •Recommended notice wording and placement
- •Evidence and documentation gaps
- •Prioritised actions and deadlines
- •Specialist review and follow-up questions
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