Yes. The Article 50(1) disclosure duty applies per channel, not just to your primary or most visible surface. The verified implementation guidance is explicit that the notice must be shown "on every channel (web chat, WhatsApp, voice, email agent, etc.) — not just your primary surface."
So if you run a branded support or sales bot on WhatsApp — built on WhatsApp Business API with a third-party AI layer, or a native integration — the same first-message disclosure requirement applies as it would on your website: tell the person, at or before the first AI message in the session, that they're talking to an AI system.
One practical wrinkle: WhatsApp's interface doesn't offer a native persistent "badge" the way a website chat widget does — there's no fixed UI element sitting next to the input field the way there is in a browser. A reasonable practical workaround (this is our operational suggestion, not wording taken from the Commission's guidance) is to put the badge-equivalent text in your WhatsApp Business profile's About/description field, which stays visible on every chat with that number, alongside the first-message notice that still needs to appear in the conversation itself.
This applies regardless of whether the underlying AI model is your own or a third party's — the provider/deployer logic that puts the disclosure duty on whoever brands the interaction applies the same way on WhatsApp as anywhere else.
It's also worth adding a human-handoff option to the WhatsApp flow itself — a simple typed keyword ("agent," or a local-language equivalent) that connects the user to a person. It isn't a strict legal requirement, but it's good practice recommended alongside the disclosure pattern, and it gives you a natural, low-friction way to demonstrate that the AI-first design doesn't trap users who'd rather speak to someone.
For evidence, treat a WhatsApp bot the same way you'd treat any other surface: a dated screenshot of the first-message notice and the profile description showing the badge text is what you'd want on hand if anyone ever asked how you've implemented the disclosure duty on that channel specifically.
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