Article 50 · Placement
Where to place an AI chatbot disclosure under Article 50
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.
Rule of thumb
Put the notice where the person starts or continues interacting with the AI — the chat widget, agent thread, or voice session — not only where lawyers and SEO look (footer, privacy, blog). Pair with clear wording and keep evidence.
Placement patterns
Pre-chat / before first message
Prefer: Gate or banner above the composer that states the user will interact with AI before they type.
Avoid: Only showing after several turns, or only after a ticket is submitted.
Persistent chat chrome
Prefer: Label in the header or sidebar (“AI assistant”) that stays visible for the whole session.
Avoid: A toast that disappears in 3 seconds with no persistent cue.
First system message
Prefer: Opening bot message that discloses AI + accuracy limits + human path — still keep a chrome label.
Avoid: Relying on a buried “About” link inside the first message only.
Mobile / widget
Prefer: Same story as desktop: visible when the widget opens, not only on the marketing site.
Avoid: Desktop-only footer disclosure while the product chat has none.
Voice / phone assistants
Prefer: Spoken notice at session start plus any visual companion UI that repeats it.
Avoid: Assuming the synthesised voice alone makes AI “obvious.”
What not to rely on alone
- Privacy policy only
- Website footer only
- Terms of Service only
- Robot emoji with no text
- Colour badge with no accessible name
- Disclosure that contradicts product behaviour (promises a human who does not exist)
Accessibility
- Text (or equivalent) available to screen readers — not icon-only
- Usable contrast in light and dark themes
- Do not hide the only notice behind a hover that mobile cannot use
Evidence of placement
For each surface: screenshot, URL or in-app path, product version, date, owner, Art. 50 paragraph mapped. Log: Article 50 evidence log. Product-specific file: Evidence Pack.
FAQ
Is a website footer enough for Article 50 chatbot disclosure?
Usually no for interaction surfaces. Article 50(1) is about informing people they are interacting with AI at the interaction — a footer on a marketing page does not cover an in-product chat. Confirm exceptions with counsel.
Does the disclosure need to appear before every message?
Not necessarily every message if a clear, persistent notice covers the session — but the person should understand they are interacting with AI before or as the interaction starts. Map your UX with counsel.
What evidence proves placement?
Dated screenshots of the live UI (desktop + mobile), product/version, owner, and which paragraph you mapped. Use the Article 50 evidence log template.