Copy you can ship tonight
The official guidelines (C(2026) 5054, 20 July 2026) give these as examples of appropriate techniques, not as the only legal wording:
You are interacting with an AI system
This is an AI-powered assistant
Use the first as a banner or persistent label next to the input field. Use the second as the first-turn greeting, or as the spoken line on a voice or IVR agent. Combine them if the surface is long or the user might forget.
Need variants for email, Slack, or a named bot? The notice copy tool is client-side and free. The $29 checklist is the print-and-tick inventory plus the 2 December marking ticket.
What the FAQ actually requires
The Commission’s Article 50 FAQ, last updated 24 July 2026, says people must be notified from the start of the first interaction, in a clear and distinguishable manner, and in line with accessibility requirements. Four cumulative tests decide if Article 50(1) applies:
- The system is an AI system.
- It is designed for a genuine two-way exchange, not just data collection or a one-shot automated reply.
- The interaction is direct: the AI talks to the person, not through a human intermediary.
- The other party is a natural person (consumer, professional, or other user).
Background, machine-to-machine, or no-direct-contact systems are out. A public support chatbot, in-app assistant, or voice agent that serves EU users is in. A US or UK HQ does not take you out if the output is used in the EU.
The “obvious” exception is narrow
You may skip the notice only if it is obvious the person is talking to AI. The FAQ says measure that against an average person who is reasonably well-informed, circumspect, and observant, and interpret the exception restrictively because it takes transparency away.
Do not treat a product-page badge, a footer, or a terms clause as enough. If a reasonably careful customer might still think a human is typing, ship the first-turn line.
Where it goes, and what is already late
| Surface | What to put | When it was due |
|---|---|---|
| Web or in-app chat | Visible banner or first-turn greeting. Keep a label near the input. | 2 August 2026. Already enforceable. |
| Voice / IVR | Spoken line at the start of the call. A tone alone is not enough (guidelines). | 2 August 2026. |
| Machine-readable mark on synthetic audio, image, video, or text | Article 50(2) provider mark, not the chatbot sentence. | 2 August 2026, or 2 December 2026 only if the system was already on the market before 2 August. |
Fines for Article 50 can reach €15 million or 3% of worldwide turnover. National market surveillance authorities handle most cases. The FAQ last-updated date is 24 July 2026.
Do this in seven days
- Ship one of the Commission example lines at first interaction if it is not already live.
- Check voice and email surfaces, not just the web widget.
- Do not open a high-risk or GPAI workstream because of this page. Those are different stacks.
- Inventory generative outputs. Open a 2 December marking ticket only if the system was on the market before 2 August.
Buy the checklist
The $29 Article 50 Ship Checklist is the print-and-tick page: inventory, the notice line, deepfake labels, and the 2 December mark. A $149 Money Brief is the right buy if you think you are in the “obvious” exception, you trained a model, or a national authority has written.
Sources
Fetched 28 August 2026 (PT). Example lines taken from the official guidelines PDF. No invented quotes.
- European Commission, Article 50 FAQ, last update 24 July 2026. Transparency obligations under Article 50 of the AI Act
- European Commission, “Commission publishes guidelines on transparency obligations,” 20 July 2026. digital-strategy.ec.europa.eu
- European Commission, “Guidelines on transparency obligations for providers and deployers of certain AI systems,” last update 6 August 2026. digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations
- Commission Decision C(2026) 5054, 20 July 2026, guidelines PDF, paragraph on format of the notifications: examples “You are interacting with an AI system” and “This is an AI-powered assistant.” AI Act Service Desk PDF