Two very different things get called "WhatsApp AI," and the Article 50(1) duty lands differently for each.
Your own automated bot on the WhatsApp Business Platform, answering customers under your business's name and profile, is your system in the eyes of the EU AI Act. Offering an AI system under your own name or brand generally makes you its provider, and the duty to disclose that customers are talking to AI sits with you. WhatsApp being the channel changes nothing; the duty applies on every channel where your AI talks to people, and the disclosure has to appear in the conversation itself (typically as the first message), not just on your website.
Meta AI, the assistant Meta itself offers inside WhatsApp under Meta's own branding, is the opposite case: that system is placed on the market by Meta, under Meta's name, and the provider-side disclosure duty for it is Meta's, not yours. Merely having Meta's features available in an app you use doesn't transfer Meta's obligations to you.
The gray zone to watch: vendor tools that let you deploy a bot which still visibly presents itself as the vendor's product, unmodified. There you may remain a deployer for that system rather than its provider. But the moment the bot carries your business name, your greeting, your persona (the common configuration), treat the disclosure duty as yours.
For a WhatsApp bot the fix is one line at the top of the conversation. The free generator produces verified first-message wording in English, German, and French.
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