Article 50 Check · by Ninth Harbor

Does Article 50 apply to Intercom, Zendesk, Tidio, or Crisp bots?

Usually, yes

These are chat-widget platforms, not a legal category the EU AI Act cares about. What decides whether Article 50(1)'s disclosure duty is on you isn't which vendor built the underlying AI — it's whose brand the customer sees.

The Act draws a hard line between provider (places a system on the market under its own name or brand) and deployer (uses a system under its own authority). The trap most SMEs fall into: if you put your own name on an API-based chatbot — built on OpenAI, Anthropic, Mistral, or similar — you are generally the provider for the disclosure duty, even though you didn't build the underlying model. This is true whichever vendor's AI feature sits underneath — Intercom Fin, Zendesk AI agents, Tidio Lyro, Crisp, or anything else.

In practice: if the widget appears on your site under your company's name, your logo, your support portal, and your bot's own name and greeting — you are functionally the provider, and the disclosure duty sits with you, not the platform vendor.

The narrower exception: if you deploy an off-the-shelf, vendor-branded chatbot completely unmodified — one that visibly identifies itself as the vendor's own product rather than yours — you remain a deployer for that system, and the Article 50(1) duty is more likely to sit upstream with the platform. In our experience this is the less common configuration; most SMEs customize the bot's name and appearance, which puts them back in provider territory.

Practical rule of thumb: if you can't point to the chat vendor's own name as the clear, visible operator of the widget your customers see, assume you're the provider and add the disclosure yourself. It's the cheapest of the four duty areas to fix — a sentence and a badge — regardless of which answer applies to you.

Not sure how this applies to your specific setup? The free 2-minute check tells you which of the four Article 50 duty areas likely apply to your company — no email required.

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