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Deadline: August 2, 2026 — 0 days

Your support AI isn't high-risk.
It has the earliest deadline anyway.

While high-risk AI got a deadline extension to December 2027, Article 50 transparency obligations did not move. If you run support chatbots, AI agents, or AI-drafted customer communications for EU users, your compliance date is August 2, 2026. That makes customer service teams some of the first in any company to face the EU AI Act.

Which customer service AI triggers Article 50?

Article 50 covers AI that interacts with people and AI that generates content people see. Customer service does both.

Support chatbots & virtual assistants

Any AI that converses with customers must disclose it's AI before or at the start of the interaction — clearly, not buried in terms of service

Autonomous AI support agents

Agents that resolve tickets, process refunds, or take actions on behalf of customers need disclosure plus logging of what they did

AI-drafted emails and replies

AI-generated text sent to customers may need marking as AI-generated — especially when sent without meaningful human review

Voice bots & AI phone systems

Synthetic voice interactions must disclose they're AI. Voice cloning of real agents adds deepfake obligations under Article 50(4)

What you actually need to do

The good news: this is days of work, not months. The bad news: most teams haven't started.

Add a clear AI disclosure at the start of every chatbot conversation
Mark AI-generated content in machine-readable format (metadata, watermarking)
Make disclosures accessible — they must work with screen readers and meet accessibility requirements
Log AI agent actions so you can reconstruct what the system did and when
Update your escalation path — customers should be able to reach a human
Document your approach: what's disclosed, where, and since when

What's not required for limited-risk AI

Limited risk means limited obligations. Don't let anyone sell you a conformity assessment you don't need.

No conformity assessment — that's only for high-risk systems
No EU database registration
No quality management system requirement
No mandatory third-party audit
Obvious AI use may be exempt — but 'obvious' is judged from the user's perspective, not yours

One caveat: if your support AI makes decisions that affect access to services — like automatically denying refunds, closing accounts, or restricting essential services — it may cross into high-risk territory. Run the classifier to check.

Using Intercom, Zendesk, or another support platform?

Their compliance doesn't automatically cover you

If you deploy a third-party AI support tool, you're a deployer under the EU AI Act — with your own obligations. The platform may provide the disclosure mechanisms, but you're responsible for making sure they're actually enabled, visible, and appropriate for your use. Check what your vendor provides, document the gap, and close it before August.

Read the deployer obligations guide →

0 days until the transparency deadline

Adding disclosures takes an afternoon. Knowing exactly which of your AI tools need them takes 5 minutes with the classifier. Start there.