Article 50 · Chatbots
AI chatbot disclosure under Article 50: wording, placement, examples, evidence
Not legal advice. ActBrief prepares a preliminary technical readiness brief for legal review and enterprise diligence — not a conformity assessment, certification, or guarantee of compliance.
1. When disclosure is typically needed
If a natural person interacts directly with your AI system (support chat, in-product assistant, agent that messages users), map the surface to Article 50(1). Exceptions and “obvious from context” are narrow — do not rely on a robot emoji alone. Confirm with counsel.
2. Example wording (starting points)
Short UI notice
You are interacting with an AI assistant. Responses may be inaccurate. A human can review escalations on request.
Product settings / about AI
AI features. [Product] uses artificial intelligence to [intended purpose]. AI outputs may be wrong or incomplete. For decisions that affect you, [human review / contact path].
Full copy-paste set: AI disclosure notice template. More variants: disclosure examples.
3. Placement (summary)
- Before first message or at session start
- Persistent label in the chat chrome (not only dismissible toast)
- Match actual behaviour — if you promise human escalation, the path must exist
- Do not bury the only notice in Terms or a footer
Deep dive — patterns, anti-patterns, mobile/voice: Where to place an AI chatbot disclosure.
4. Accessibility
Text must be readable by assistive tech; colour alone is not enough; keep contrast usable in dark/light themes.
5. Evidence checklist
- Screenshot of live disclosure (desktop + mobile if different)
- Product name / version / release date
- Owner and approval date
- Mapped Article 50 paragraph + provider/deployer role
- Link to Commission guidelines version you used
Spreadsheet-style log: Article 50 evidence log. Product-specific file: Article 50 Evidence Pack. Checklist form: Article 50 checklist.
6. Related questions
Does every SaaS chatbot need an AI disclosure?
Often yes when natural persons in the EU interact with the system and Article 50(1) applies. Obligations have applied since 2 August 2026. Confirm paragraph, actor, and exceptions with counsel.
Where should the disclosure appear?
At the point of interaction — before or at the start of the chat — not only in a footer or privacy policy. See the dedicated placement guide for UI patterns and anti-patterns.
What evidence should we keep?
Screenshot of the live UI, product/version, release date, owner, approval note, and which Article 50 paragraph you mapped the surface to. Use the Article 50 evidence log template or Evidence Pack.