Article 50(1) of the EU AI Act requires that AI systems interacting directly with natural persons inform those people they're dealing with AI — unless it would already be obvious to a "reasonably well-informed, observant and circumspect" person in context.
"Obvious" is judged against your actual audience, including vulnerable groups like children, the elderly, or low-literacy users if they're a foreseeable part of who you serve. Examples treated as obvious without any notice: developer-only code assistants, game NPCs. Examples treated as not obvious by default: embedded helpdesk and support chatbots — the exact use case most SMEs run.
Timing: the notice must appear at the latest at first interaction, for each person, and persistently where appropriate.
What counts as valid: a first-turn written notice, a persistent badge near the chat interface, a spoken statement at the start of a voice call, or a combination of these across channels.
What doesn't count on its own: burying the disclosure in terms & conditions or documentation, a machine-readable-only mark with no human-visible signal, or an audio earcon alone.
What's out of scope entirely: human agent-assist, where AI drafts a reply but a human reviews and sends it, is not covered by Article 50(1) — only fully automated responses trigger the duty.
For the exact wording to paste — badge text and first-message notice in English, German, and French — use the free disclosure generator.
Two implementation details worth building in from the start: make the disclosure accessible — a screen-reader label, not a colour-only cue — and simplify the language for minors if children are a foreseeable part of your audience. Both come from the same implementation guidance the disclosure pack is built on, and both are cheap to add at build time versus retrofitting later.
It's worth being precise about what this duty is not. It isn't a certification requirement, a technical standard, or a demand for a particular vendor's tooling — it's a disclosure obligation, satisfied by clear, visible, well-timed language. Companies that over-engineer their response to this duty are usually solving a harder problem than the one the Regulation actually poses.
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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