Chatbot Labeling under Art. 50: 5 Practical Implementations

· Category: EU AI Act · Reading time: 3 min · As of 2026-05-02
Practitioner note: This is not legal advice. For specific situations, consult a qualified attorney or compliance officer.

TL;DR

  • Art. 50 chatbot disclosure mandatory from Aug 2, 2026 — not affected by the Digital Omnibus proposal (Nov 19, 2025; trilogue ongoing, NOT adopted)
  • Disclosure at conversation start, in plain language, prominently visible
  • 5 channels covered: web chat, voice IVR, Discord/Slack, WhatsApp Business, in-app
  • Always offer human escalation — "type Human" or equivalent
  • Fine risk: up to 15M EUR / 3% global revenue

1. Web chat (live-chat widget)

First bot message: "Hi! I am the AI assistant for [Company]. I will answer your questions — if I cannot help, I will hand you over to a colleague." Place a small "AI" badge in the chat header. Persist across sessions.

2. Voice bot (telephone IVR)

Greeting: "You are speaking with an AI assistant for [Company]. Say 'human' at any time to reach an advisor." Respeak the disclosure if the caller is transferred between bot flows.

3. Discord / Slack bot

Bot profile carries an "AI" or lightning-bolt indicator. Bio: "AI assistant. Replies are AI-generated." Prefix the first reply in any thread with "[AI note]:". Use platform-native bot APIs so the user-agent indicates a bot.

4. WhatsApp Business AI

On first contact: "Welcome to [Company]. You are chatting with an AI bot. To reach a human, send 'human'." Include the disclosure in the WhatsApp Business profile description as well.

5. In-app chat

UI shows a bot icon and the label "AI assistant". The first bubble carries the note "AI-generated. We escalate to support when needed." Make sure screen-reader text repeats the disclosure for accessibility.

Summary

Five channels, one rule: disclose at the start, in plain words, with an easy human-escalation path. The Art. 50 obligation is a small UX change with a large compliance impact — ship it well before Aug 2, 2026. Add the disclosure language to your Acceptable Use Policy so vendors deploying bots in your name follow the same standard.

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Frequently Asked Questions

Is one notice per session sufficient?
Yes, at the beginning. For long conversations (more than 30 minutes), a refresher is recommended.
What about voice bots without visualization?
A verbal greeting is mandatory — it cannot be omitted.
Fines for violations?
Up to EUR 15 million / 3% pursuant to Art. 99 para. 4 lit. b.

Sources

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