From 2 August 2026, Article 50 of the EU AI Act requires that people interacting with an AI system — a website chatbot, a voice agent on the phone, an AI assistant in an app — are told they are dealing with AI, unless it is obvious from the context. If your Irish business runs a customer-facing chatbot, the fix is usually a few lines of disclosure copy, but it needs to be in place before the deadline, on every channel where the bot appears.
What Article 50 requires
Article 50(1) of the AI Act (text on EUR-Lex) requires that AI systems intended to interact directly with people are designed so that the people concerned are informed they are interacting with an AI system, unless this is obvious to a reasonably well-informed, observant person from the circumstances. The duty is deliberately lighter-touch than the high-risk regime — no conformity assessments, no logging mandates — but it is universal for systems in scope, whatever their risk level. A product-questions chatbot that is otherwise minimal risk still needs the disclosure.
Which of your systems are caught
- Web chatbots — customer service, sales and FAQ bots on your site.
- Voice agents — AI answering or making phone calls, taking bookings, routing queries. Voice deserves particular care, because a caller has fewer contextual clues than a website visitor.
- Messaging-channel bots — AI responding to customers on WhatsApp, Instagram or SMS, where the customer may assume a human is typing.
- In-app assistants — AI helpers embedded in your product or customer portal.
The “obvious from context” carve-out is narrower than it sounds. A tool literally branded as an AI assistant may qualify; a chat widget that says “Chat with us” and answers in a conversational tone almost certainly does not. The safe approach is to disclose and stop relying on the exception.
What good disclosure looks like
- Label the entry point — “AI assistant” on the widget or menu, not a vague “Chat with us”.
- State it in the opening message: “You’re chatting with our AI assistant.” For voice agents, say it at the start of the call.
- Keep it in plain language — the test is whether an ordinary customer understands, not whether a lawyer would.
- Offer the human route where one exists, which is good practice and defuses most complaints.
- Walk every journey where the bot appears — site, app, messaging, phone — and record the check. The disclosure must be present on each.
The companion deadline: content labelling
Article 50 has a second limb arriving on 2 December 2026: AI-generated images, audio and video, and AI-written text published to inform the public, must be identifiable as AI-generated. If your marketing pipeline uses generated imagery or AI-drafted articles, the labelling workflow is worth building at the same time as the chatbot disclosure. Both duties apply whether you built the bot or bought it — though your exact position depends on whether you are a deployer or a provider.
Get August 2026 off your worry list
Record your chatbot in AI Register Ireland and the Article 50 duties appear against it with the 2 August 2026 deadline attached — alongside every other obligation in your AI Act timeline. Plans for Irish SMEs start small — see pricing.