Zum Inhalt springen
Individually trained
Recht & Compliance

EU AI Act 2026: Chatbot Disclosure Duties Explained

From 2 August 2026, Article 50 of the AI Act applies: users must be able to tell they are chatting with an AI, not a human. What it means for your website chat.

11 min read EU AI ActTransparenzKI-AssistentComplianceKennzeichnung

On 2 August 2026 an announcement becomes binding law: that is when the transparency obligations under Article 50 of the AI Act, the EU's Artificial Intelligence Regulation, start to apply. The core is quickly explained and affects almost every website with a chat: anyone using an AI assistant that communicates directly with people must ensure those people can tell they are writing with a machine and not with a human. The regulation already entered into force on 1 August 2024 (European Commission), but its rules apply in stages; the transparency obligations for chatbots become applicable from 2 August 2026 (European Commission). This is no academic matter: in Germany, 41 percent (Bitkom) of companies now actively use AI, twice as many as in 2024 with around 20 percent (Bitkom), and a growing share of them talks to customers directly through a chat window. This article explains, in practical terms, what Article 50 means for a website chat, what a clean AI disclosure looks like, why handover to a human belongs with it, what documentation the market surveillance authority expects and what a breach can cost. It does not replace legal advice, but it offers reliable guidance for the deadline.

EU AI Act · Article 50 · Disclosure DutyTransparency for AI chats from 2 August 2026Your Website AssistantAINotice: you are chatting with anAI assistant, not with a human.Am I talking to a human here?No, I am the AI assistant. Fortricky cases I bring in a colleague.Hand over to a humanDisclosure shown before the first messageWrite a message ...How to meet Article 50AI notice before first contactClearly visible in the widget, not the footerHandover to a human at any timeOne click from chat to a staff memberAccessible and distinguishableLegible, high-contrast, clearly namedDocumentation for market surveillanceEvidence for the supervisory authorityBreach of Article 50: fines up to EUR 15m or 3 % of turnoverMarket surveillance in Germany: Bundesnetzagentur

What Applies From 2 August 2026

The AI Act does not take effect all at once but in stages. After it entered into force on 1 August 2024, the bans on certain AI practices applied first, followed by obligations for general-purpose AI models. The transparency obligations under Article 50, which cover chatbots and AI-generated content, become applicable on 2 August 2026 (European Commission). By that date, a website chat should be set up to meet the requirements. For operators this means the clock is ticking, and the effort is manageable if you address it in good time instead of retrofitting just before the deadline.

Article 50 distinguishes between providers and deployers. Providers are those who develop and supply the AI system; they must design the chatbot technically so that disclosure is possible. Deployers are the companies that use the assistant on their website; they are responsible for ensuring the disclosure is actually visible in the specific use. In the practice of a website chat, both roles often coincide or interlock closely. The consequence matters: neither the provider nor the deployer can point to the other. Both sides should clarify from the outset who fulfils which obligation.

Briefly explained: who Article 50 applies to

Article 50 concerns AI systems intended to interact directly with natural persons, that is, classic website chatbots, virtual assistants and automated telephone systems. An exception applies only where it is obvious to a reasonably well-informed and attentive person that they are speaking with an AI. Because hardly anyone can rely on that in everyday use, the safe assumption is: a website assistant needs an explicit, visible disclosure.

Article 50: the Four Transparency Duties at a Glance

Article 50 bundles several transparency rules that look different at first glance but share a common goal: people should know when they are dealing with AI. For a website chat, the first duty is decisive; the others concern AI-generated content and are also relevant depending on the use.

Chatbot disclosure (Art. 50(1))

Users must be informed that they are interacting with an AI, and in good time before or at the very beginning of the conversation.

Marking AI content (Art. 50(2))

Text, images, audio or video generated by generative AI must be marked in a machine-readable format as artificially generated.

Emotion and biometric systems (Art. 50(3))

Anyone using emotion recognition or biometric categorisation must inform the individuals exposed to it.

Disclosing deepfakes (Art. 50(4))

Artificially generated or manipulated image, audio and video content, so-called deepfakes, must be identified as such.

For chatbot disclosure under paragraph 1, the deadline of 2 August 2026 applies without delay. For the machine-readable marking of AI-generated content under paragraph 2, the European Commission provides a short transition period until 2 December 2026 (European Commission) for systems that were already on the market before that date. A website assistant that mainly answers questions and guides visitors to the right offer usually falls under chatbot disclosure; if it also produces visible AI content, the marking duty is added.

Why Users Must Know They Are Writing With an AI

The idea behind disclosure is simple: those who know an AI is answering at the other end can classify the answers correctly and decide consciously which questions to ask and which details to share. This is no theoretical concern, because AI assistants are becoming everyday tools. According to Bitkom, 44 percent (Bitkom) of AI users turn to the technology for private questions and 34 percent (Bitkom) even for health-related matters. At the same time, Gartner expects that by 2026 around one in ten service interactions will be fully automated, up from around 1.6 percent (Gartner) before. The more natural AI chat becomes, the more important it is that no one is left unclear about the nature of their counterpart.

People should be informed that they are interacting with an AI so that they can decide with knowledge of the circumstances.

In line with the recitals on Article 50 of the AI Act

For companies, disclosure is more than a duty. A visible, honest notice builds trust and removes the uncertainty from the interaction. Visitors who know they are talking to an assistant often phrase things more clearly and are less disappointed when a question is passed to a human. Transparency and a good chat impression are therefore not a contradiction. How an individually trained assistant differs from a generic standard chatbot is shown in the article on the difference between a custom assistant and a standard chatbot.

What This Means Concretely for Your Website Chat

Article 50 and the accompanying European Commission guidelines yield some concrete requirements for a website chat. They sound technical, but they are manageable to implement if you consider them from the outset rather than afterwards.

  • The notice appears in good time, that is, before or at the beginning of the conversation, not only after several messages (European Commission).
  • The disclosure is clear and distinguishable, not hidden in a tiny footer text or buried in the terms and conditions (European Commission).
  • The notice is designed to be accessible and thus perceivable by people with impairments too.
  • The assistant remains recognisable as an AI throughout and does not pretend to be human.
  • For sensitive or legally delicate matters, a handover to a human is provided.
  • The deployer can demonstrate that the disclosure is actually visible in use.

The European Commission guidelines also state explicitly what does not suffice: a tiny snippet of text in the footer, a faint, barely legible label or a notice buried in the terms and conditions. Such token labels do not meet the requirement for clear and distinguishable information. For a website chat this means the notice belongs visibly at the start of the chat window, in plain language and with sufficient contrast. A transparently labelled assistant should also answer reliably instead of speculating freely; how to avoid false answers through a well-maintained knowledge base is shown in the article avoiding hallucinations with a knowledge base.

Clear Disclosure in the Widget: What It Looks Like

In practice, disclosure can be implemented with a few but deliberate decisions. What matters is that the notice appears where the visitor is already looking, namely in the chat window itself, and before the first question is answered.

Notice before first contact

As soon as the chat opens, a clear sentence appears stating that an AI assistant is answering here, not a human.

Visible, not hidden

The disclosure sits prominently in the widget and not in the footer or terms and conditions, as the guidelines require.

Accessible and legible

Sufficient contrast, plain language and a screen-reader-friendly implementation make the notice perceivable for everyone.

Technically the disclosure is no major intervention, but it wants to be designed deliberately. The notice should appear in the visitor's language, which a multilingual assistant handles automatically, and it should meet the same accessibility standards as the rest of the website. How the integration embeds the assistant cleanly into an existing page without disturbing the layout is described in the relevant article. And how to make an assistant fully accessible in line with accessibility legislation is shown in the article on the accessible AI assistant under the BFSG.

Disclosure belongs at the start, not the end

Check your chat from the perspective of a first-time visitor: is it immediately clear on opening that an AI assistant is answering? A notice you only find after scrolling or in a linked document does not serve the purpose. The best place is the first visible line in the chat window, supplemented by a permanently recognisable AI label.

Handover to a Human at Any Time

Article 50 requires disclosure, not necessarily a human handover. In practice, however, the two belong together. An assistant that openly appears as an AI should also offer a way to switch to a human as soon as a matter becomes too sensitive, too complex or legally delicate. This is no contradiction to automation but its sensible frame: the assistant handles the frequent, clearly answerable questions, and a human is available for everything else. According to Gartner, exactly this combination lowers contact-centre costs; the firm expects conversational AI to bring relief of around 80 billion dollars (Gartner) in 2026, without human contact disappearing.

Plan handover as a fixed component

Define in advance for which topics the assistant hands over to a human, for example complaints, contract or health questions. A visible button in the chat that lets visitors request a human at any time makes the boundary of automation transparent and strengthens trust on top of the disclosure itself.

A good handover passes along the previous conversation so the human does not start from scratch. That keeps the matter flowing even though the channel changes. Which questions the assistant can reliably handle itself and where a handover makes sense can be read over time from real conversations; how that works is shown in the article on analysing chat transcripts. How an assistant relieves support overall without replacing the human is described in the article on the support assistant.

Documentation for Market Surveillance

Transparency obligations are only worth as much as they can be demonstrated when in doubt. The AI Act requires member states to designate at least one market surveillance authority by 2 August 2025 (AI Act). In Germany, the Bundesnetzagentur (Bundesnetzagentur) takes on this role, with a coordination and competence centre for the AI Act being set up that supports other competent authorities and is intended to ensure a uniform interpretation. The German Bundestag adopted the necessary national supervisory structure in the AI Act implementation law (German Bundestag).

For operators of a website chat this means it is worth recording your own implementation in a traceable way. This includes how and where the AI disclosure is shown, when it appears, how the handover to a human is arranged and which system sits behind the assistant. This documentation need not be a thick manual, but in the event of a market surveillance enquiry it should be able to show that the assistant meets the requirements of Article 50. Those who have the assistant operated by a service partner should clarify that the partner provides the necessary evidence and technical details.

Consider provability from the outset

A disclosure that is visible but documented nowhere is hard to prove in an emergency. Record since when which version of the notice has been in use. That way you can demonstrate to the Bundesnetzagentur in a traceable manner that the chat meets the transparency obligations, without having to reconstruct afterwards what applied when.

Fines: What a Breach Costs

The AI Act provides for tiered fines in Article 99. A breach of the transparency obligations under Article 50 can be penalised with up to 15 million euros (Art. 99 AI Act) or three percent of global annual turnover, whichever is higher. For breaches of the prohibited AI practices under Article 5, the ceiling is even 35 million euros (Art. 99 AI Act) or seven percent of turnover, and incorrect or misleading information to authorities can be penalised with up to 7.5 million euros (Art. 99 AI Act) or one percent.

BreachCeilingClassification
Prohibited AI practices (Art. 5)35m euros or 7 % of turnoverHighest tier
Breach of transparency (Art. 50)15m euros or 3 % of turnoverCovers website chats
Incorrect information to authorities7.5m euros or 1 % of turnoverDuties to provide information

The regulation emphasises that fines should be effective, proportionate and dissuasive and take into account the situation of small and medium-sized enterprises; for them the lower of the two values applies. Whether and at what level a fine is imposed depends on the individual case, and the ceilings are theoretical maxima, not standard penalties. The real point is different: the requirement itself is achievable with manageable effort. It is much easier to set up a chat transparently from the start than to have to react later to a complaint or an inspection.

Standard Widget or Transparent by Default

Many off-the-shelf chat widgets can be fitted with a disclosure notice after the fact. The difference lies in whether transparency is a detail screwed on afterwards or considered from the outset. An assistant that already brings the AI disclosure, the handover to a human and the necessary documentation saves retrofitting and makes the implementation traceable for market surveillance.

AspectRetrofitted standard widgetXICBOT assistant
AI disclosureOptional, often in the footerVisible before the first contact
Handover to humansNot always providedA fixed component with context
AccessibilityDepends on the providerLegible, high-contrast, accessible
DocumentationTo be compiled yourselfTraceable details on the use
HostingOften outside the EUHosting in Germany

XICBOT assistants are labelled as AI by default, with a clean handover to a human and hosting in Germany. That way the disclosure duty is not a makeshift solution but part of a considered setup. How data protection and the server location interplay is shown in the article on data protection and hosting; the technical foundation of an AI assistant is explained in the article what is an AI chat assistant. Which package fits is shown in the pricing overview. We do not promise absolute legal certainty, but a concept that takes the transparency obligations seriously from the start.

Your Checklist for the Disclosure Duty

From the points so far, a manageable list of questions emerges that should be clarified before 2 August 2026. It does not replace individual legal advice but offers reliable guidance on whether a website chat is set up transparently.

  • Do visitors recognise before or at the beginning of the conversation that they are writing with an AI?
  • Is the notice visible in the widget and not in the footer or terms and conditions?
  • Is the disclosure accessible, that is, legible, high-contrast and screen-reader-friendly?
  • Does the assistant offer a handover to a human at any time?
  • Is it documented how and since when the disclosure is shown?
  • Does the notice appear in the visitor's language?
  • Is it clear who is the provider and who is the deployer and who fulfils which obligation?
  • Does the assistant produce AI content that additionally has to be marked in a machine-readable way?

2 August 2026 is no reason for nervousness, but a good occasion to look at your own website chat from the perspective of the transparency duty. Those who answer the few points on this list cleanly operate their assistant on a solid basis. Which setup suits your sector is best clarified in a conversation; an overview of typical fields of use is given on the page on industry solutions, and specific questions are answered by direct contact.

Sources and studies

This article is based on data from: Regulation (EU) 2024/1689 on artificial intelligence (the AI Act, in particular Article 50 and Article 99), the guidelines and information from the European Commission on the transparency obligations, information from the German Bundestag and the Bundesnetzagentur on national supervision, Bitkom (AI use among companies and consumers) and forecasts from Gartner (automation in customer service). The figures and dates mentioned can change and may differ depending on the source. This article does not replace individual legal advice; absolute legal certainty cannot be promised.