Chatbots and Article 50: telling customers it is an AI (Irish SMEs and EU teams based in Ireland)

Last checked: 20 Oct 2026 · Ireland · Regulation (EU) 2024/1689, Art. 50

Short answer. Since 2 August 2026, Article 50(1) of the EU AI Act requires that people are told when they are interacting with an AI system (website chatbot, WhatsApp assistant, phone bot), unless that is obvious to a reasonably well-informed, observant and circumspect person, taking into account the circumstances and the context of use. The duty sits with the provider of the system. High-risk rules do not apply from August 2026: Annex III from 2 December 2027, Annex I from 2 August 2028 (Regulation (EU) 2026/1744).

One next step: Create a ready-to-paste Article 50 notice (chatbot and other cases) with the free Art.50 notice generator (runs in your browser; nothing is uploaded). Then add the chatbot to the EURO AI Register (free for up to 10 AI systems).

Who has to tell users?

Article 50(1) is addressed to providers of AI systems intended to interact directly with natural persons: the system must be designed and developed so that users are informed they are talking to an AI. Ireland has two very different groups here:

Irish SMEs using a vendor chatbot (GP or dental practice, letting agent, hotel or B&B, gym, online shop, accountancy practice): check that the vendor's widget already shows a notice in the first message; if not, add one yourself. It is the simple, low-risk route.
Software companies and EU headquarters based in Ireland that build a chatbot or assistant and offer it under their own name to customers across the EU: you are likely the provider, so the notice must be designed into the product for every market and every language you serve, not added later by each client.

When does it apply?

Article 50 (transparency): from 2 August 2026 (general date of application, Art. 113 Regulation (EU) 2024/1689).
Machine-readable marking (Art. 50(2)) for generative systems already placed on the market before 2 August 2026: by 2 December 2026 (new Art. 111(4) inserted by Regulation (EU) 2026/1744).
High-risk: not August 2026 — 2 Dec 2027 (Annex III) / 2 Aug 2028 (Annex I).

What should the notice say?

Article 50(1) requires informing the person that they are interacting with an AI system. In practice: one short, visible sentence at first contact, for example “You are chatting with an AI system, not a person. You can ask for a member of staff at any time.” Article 50(5) requires the information to be clear and distinguishable, at the latest at the first interaction, and accessible. A line hidden in your privacy notice does not appear in the chat window, so show it there. If you serve customers in Irish or in other EU languages, show the notice in the language of the conversation. Your GDPR transparency duties still apply alongside it (Art. 50(6)).

Exceptions ('obvious' and others)

Obvious from the context: the duty does not apply where it is obvious to a reasonably well-informed, observant and circumspect person that they are dealing with an AI. A short notice is still the cautious choice.
Systems authorised by law to detect, prevent, investigate or prosecute criminal offences (with appropriate safeguards): outside paragraph 1, unless they are available to the public to report a criminal offence.

Examples from Irish businesses

GP or dental practice: appointment assistant on the website or phone line — notice when the chat opens or at the start of the call.
Letting agent / estate agent: bot answering questions on rental listings — say replies are AI-generated and may contain errors.
Hotel, B&B or tour operator: booking assistant for visitors from many countries — show the notice in the guest's language.
Accountancy practice: FAQ assistant for clients during tax-return season — do not give the impression a staff member is answering live.
Dublin SaaS company: support or sales assistant sold to clients across the EU — build the notice in as a default setting clients cannot silently remove.

Which authority in Ireland?

Ireland uses a distributed model. The European Commission list names the AI Office of Ireland (Oifig IS na hÉireann) as Ireland’s single point of contact for market surveillance; on the list checked on 20 Oct 2026 (last updated 7 September 2026) the entry carries no “pending” marker. The AI Office is set up under the Regulation of Artificial Intelligence Act 2026 to coordinate implementation (Department of Enterprise, Tourism and Employment). Existing sectoral regulators are designated as market surveillance authorities by S.I. No. 366 of 2025 as amended by S.I. No. 405 of 2026, so the relevant regulator depends on your sector. Unlike the GDPR, do not assume a single lead authority for an Irish-based provider: AI Act market surveillance is organised per Member State. Check the current status on the European Commission list.

FAQ

Our vendor's chatbot already says “AI assistant”. Is that enough?

If the message makes clear from the first contact that the user is talking to an AI, you are close to paragraph 1. Check that it is visible and accessible (Art. 50(5)). Not legal advice.

We are the EU headquarters of a company that sells a chatbot across Europe. Which language should the notice use?

The AI Act does not fix one language for this notice. The practical answer is the language of the conversation in each market, built into the product by the provider.

Do high-risk rules also apply from August 2026?

No. Under Regulation (EU) 2026/1744, Annex III applies from 2 December 2027 and Annex I from 2 August 2028. Article 50 is separate.

Is this an official EU or Irish government tool?

No. Unadhi EURO AI pages and tools are not legal advice and not an official EU or Irish government publication.

Summary

Ireland: From 2 August 2026, Article 50(1) of Regulation (EU) 2024/1689 requires providers of AI systems intended to interact directly with people (chatbots, voice assistants) to inform users that they are interacting with an AI system, unless that is obvious from the context to a reasonably well-informed, observant and circumspect person. Show information clearly at the latest at the first interaction (Art. 50(5)). High-risk rules are not from August 2026: Annex III from 2 December 2027, Annex I from 2 August 2028 (Regulation (EU) 2026/1744). The Commission’s MSA list names the AI Office of Ireland as Ireland’s single point of contact (no pending marker on the list checked 20 Oct 2026); sectoral regulators act as market surveillance authorities (S.I. No. 366 of 2025 as amended). Free: Art.50 notice generator and EURO AI Register (free for up to 10 AI systems). Not legal advice; not an official EU tool.

Official sources

This is not legal advice. It is an independent explanation, not a publication of the EU, the AI Office of Ireland or any public body. The legally binding text is the Official Journal version. The generator and the Register are record-keeping aids, not proof that you meet the rules. Last checked: 20 Oct 2026. Official text checked against the Official Journal via the Publications Office cellar on 14 Oct 2026.

Prepared by the Unadhi EURO AI team. Written with AI, reviewed by humans. This is not legal advice.