Can we disclose only in English?

Article 50(5) requires accessibility; it does not pick a language. If you already localise the product, localise the disclosure. The Commission guidelines discuss distinguishability and first-interaction timing — read them for the UI cases you actually ship.

Does a system voice that says “I am an AI” once count?

Once, at the first interaction, can be enough if it is clear, distinguishable, and accessible. A one-shot audio cue with no visual equivalent fails users who cannot hear it. Pair modalities.

AI disclosure for chatbots under Article 50(1)

Article 50(1) is a design duty, not a privacy-policy duty. The person must be informed they are interacting with an AI system at the latest at the first interaction, in a clear and distinguishable way that meets accessibility requirements. A buried terms link does not do that work.

Educational resource only — not legal advice. scm.cc publishes a readiness report and engineering gap analysis for AI features. It does not give legal advice, represent you before a regulator, or state that a product is ready to ship under any law. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.

Last checked against official sources: 2026-10-11.

What the official text actually requires

Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed so those persons are informed they are interacting with an AI system, unless this is obvious from the point of view of a reasonably well-informed, observant and circumspect person, taking into account the circumstances and the context of use. Information under Article 50(5) is provided clearly and distinguishably, at the latest at the first interaction or exposure, and conforms to applicable accessibility requirements.

A disclosure that survives the obviousness test

Put the words next to the composer, not in the footer. Name the system as an AI system. Do not give it a human first name without the AI label. If the same surface can hand off to a human, say so — that is useful, and it also makes the AI turn distinguishable.

Copy you can ship (preview)

“You are interacting with an AI system. Replies are generated automatically and can be wrong. A human can take over — use the Hand off control.” Pair it with the React snippet on the template page. That copy is a starting point, not a finding that your product meets Article 50.

Questions teams ask

Can we disclose only in English?: Article 50(5) requires accessibility; it does not pick a language. If you already localise the product, localise the disclosure. The Commission guidelines discuss distinguishability and first-interaction timing — read them for the UI cases you actually ship.
Does a system voice that says “I am an AI” once count?: Once, at the first interaction, can be enough if it is clear, distinguishable, and accessible. A one-shot audio cue with no visual equivalent fails users who cannot hear it. Pair modalities.

Back to the AI law hub

Primary sources

Official text wins. Last checked 2026-10-11. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.