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How to · 9 min read

Chatbot disclosure under the EU AI Act. A step-by-step how to

Every chatbot operator in Europe has the same six steps to run before August 2, 2026. This is the practical how to.

Step 1. Identify every chatbot you operate

Start with the obvious ones (your website widget, your Facebook Messenger auto reply, your WhatsApp Business AI), then look for the less obvious ones (your support email auto-classifier, your AI booking assistant, the GPT inside your CRM that drafts customer replies). Each separate AI surface that interacts with humans is one disclosure obligation.

Use ActHub's AI Inventory to keep this list current. Vendors evolve quickly. Slack, HubSpot, and Intercom all added AI replies in the past 12 months.

Step 2. Draft the disclosure line

The line should be short, factual, and offer a way out. Three examples that work.

  • "You are chatting with an AI assistant. Type 'human' at any time to talk to a person."
  • "This conversation is handled by AI. For complex issues, click here to start a real human chat."
  • "Hi, you are speaking with an AI voice assistant. Say 'agent' to reach a person."

What to avoid: jargon ("LLM", "GPT-powered"), euphemisms ("smart assistant"), or buried fine print. Plain language. One sentence.

Step 3. Place the disclosure at first interaction

The disclosure must appear before the user's first message, or together with the agent's first reply. Three common patterns.

  1. Pre-chat banner. A line above the input field that says "You are chatting with AI" with a small icon. Works for Intercom, Drift, Crisp, custom widgets.
  2. First message disclosure. The chatbot's first message contains the disclosure. Works on every platform but relies on the message actually firing first.
  3. Inline label. A persistent label in the chat header that says "AI". Helpful for long sessions where the disclosure scrolls out of view.

ActHub's Disclosure Widget ships with all three patterns. Pick the one your chat platform supports and paste the embed script in your site footer.

Step 4. Make the disclosure accessible

Use a colour contrast that passes WCAG AA (4.5:1 for normal text). Add an ARIA live region so screen readers announce the disclosure. Avoid colour-only signalling. The ActHub widget handles all three by default.

Step 5. Localise into every language you serve

The disclosure must appear in the language of the user. If your site auto-detects language for the rest of the page, the disclosure should follow the same logic. ActHub ships ready disclosure templates in English, German, French, Spanish, Italian, Dutch, Polish, and Romanian. See the Templates Library inside the app.

Step 6. Save evidence

Take a screenshot of the disclosure in each language. Save the date. Save the URL. Store everything in a single folder you can hand to an auditor in 30 seconds. Use the Article 50 Checklist to track which evidence you have collected, and the Compliance Dossier PDF to roll everything into one signed file.

Real-world chatbot setups, and how to comply with each

Intercom Fin or Resolution Bot

Open the Intercom settings, navigate to Messenger, edit the welcome message. Paste the disclosure line. Save. Take a screenshot. Done.

Custom GPT-based chatbot

Add the disclosure to the system prompt so the model includes it in the first reply: "Begin every conversation with this line: You are chatting with an AI assistant. Type 'human' to talk to a person." Also add a static banner above the input box.

WhatsApp Business with AI auto-reply

Configure the welcome message in WhatsApp Business to include the disclosure. Configure the away message similarly. The customer sees the disclosure within their first message exchange.

Voice agent on the phone

The first sentence the AI says must contain the disclosure. Example: "Hello, you are speaking with an AI voice assistant for Acme Bakery. How can I help today?" Record the intro, save the script, log every call's start with the disclosure flag set.

Common mistakes that fail the requirement

  1. Burying it in the terms of service. The Act is explicit that the disclosure must be at the point of interaction, not buried in a document nobody reads.
  2. Counting "Powered by ChatGPT" as a disclosure. A vendor badge is not a user-facing AI disclosure. The user needs to understand they are talking to AI, not which model brand is behind it.
  3. Only showing the disclosure once on page load. If the user returns to the chat 30 minutes later, the disclosure should still be visible. Use a persistent label.
  4. Only English on a multilingual site. If the user is browsing in French, the disclosure should be in French.
  5. Skipping mobile. The mobile widget often has its own welcome flow. Test it.

Where to go next

Sources