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Telling people it's AI: Article 50.

From 2 August 2026, chatbots and voice agents used with people in the EU have to make clear they are AI. It is a small design change with a big trust effect.

Short answer

Yes. Under Article 50(1) of the EU AI Act, AI systems that interact directly with people must be designed so those people are informed they are dealing with an AI system, unless that is obvious from the context. The obligation applies from 2 August 2026, a date the Digital Omnibus left unchanged. For a business this means: introduce the WhatsApp, chat or phone agent as an AI assistant at the start, keep that clear throughout, and offer a way to reach a person, which Dutch regulators AP and ACM also expect.

Who must do what

Article 50 in four lines.

ParagraphWhoObligation, simplified
50(1)Providers of AI that talks to peopleDesign it so people are told they are interacting with AI, unless obvious.
50(2)Providers of generative AIMark AI-generated audio, image, video or text output in a machine-readable way. As reported, systems already on the market before 2 August 2026 have until 2 December 2026.
50(3)Deployers of emotion recognition or biometric categorisationInform the people exposed to it.
50(4)Deployers of deepfakes, or of AI text published to inform the publicDisclose that the content is AI-generated or manipulated, with exceptions.

Simplified reading of Article 50 for orientation; see the official text for the exact conditions and exceptions.

In practice

How we implement it per channel.

01WhatsApp

The first reply names the assistant: for example, an AI assistant of your business, and how to reach a colleague.

02Web chat

A label on the chat window plus the same opening line; the hand-off button is always visible.

03Phone

The voice agent says it is an AI assistant before anything else, and transfers on request.

04Email drafts

Drafts approved and sent by staff are your staff's messages; fully automatic replies say they are automated.

05Logs

Disclosure and hand-off requests are logged, so you can show how it works.

Beyond the EU

The same standard in the Gulf.

UAE, Saudi and Qatari law do not have an Article 50 equivalent written in the same way. We apply the same disclosure anyway: customers in Dubai notice when a reply comes at 2 a.m., and saying it is an assistant avoids the feeling of being misled.

In the Netherlands, the AP and the ACM said in October 2025 that organisations must make clear when someone is dealing with a chatbot, must not give wrong or evasive information through it, and must always offer the option of speaking to an employee.

Note

Not legal advice.

This guide is general information, checked against the sources listed, and not legal advice. Rules change; check the current text or ask a lawyer before you rely on it. Checked November 2026.

FAQ

Common questions.

When is it 'obvious' that it is AI?

The Act gives the exception, not a list. A clearly labelled voice assistant may be obvious; a WhatsApp message that reads like a colleague is not. We do not rely on the exception.

Does this apply to a business in Dubai?

It applies when the system is used with people in the EU. A Dubai business serving only UAE customers is outside it, but the practice is still sensible.

Is there a fine?

The AI Act sets penalty tiers, and transparency obligations fall under them. This is general information, not legal advice.

Does Article 50 make our chatbot high-risk?

No. Transparency obligations are separate from the high-risk rules. A customer-service agent is usually not high-risk.

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