Chatbots, AI assistants, generated content, and deepfake-like media are usually not high-risk by default, but they often trigger Article 50 transparency obligations.
For product teams, the rule is practical: users should know when they are interacting with AI or consuming AI-generated content unless the AI nature is obvious.
Disclosure is relevant when an AI system directly interacts with people or generates content that could be mistaken as human-created.
Use clear interface labels, first-message disclosure, metadata where appropriate, and audit logs showing when disclosure text was shown.
If the chatbot makes or materially influences decisions in employment, education, credit, insurance, public benefits, or essential services, assess whether the system moves from transparency-only into high-risk territory.
Most user-facing chatbots should disclose that users are interacting with AI unless this is obvious to a reasonable person in context.
No. Article 50 is a transparency obligation. A chatbot can still become high-risk if it is used in high-risk domains or materially influences important decisions.
A good disclosure is visible, timely, and plain-language, such as a first message or header label that says the user is interacting with an AI assistant.
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