SiteProof AI Blog
Chatbot Disclosure Requirements in 2026: What Your Website Must Show
If your website uses a chatbot, EU AI Act Article 50 requires you to clearly inform users they are interacting with an AI system — unless it is already obvious. This obligation applies to any business whose chatbot is accessible to EU users, regardless of where the company is located. Six US states have passed similar laws effective 2025–2026.
What Is the EU AI Act Chatbot Disclosure Requirement?
Article 50(1) of Regulation (EU) 2024/1689 states:
“Providers and, where applicable, deployers of an AI system that is intended to interact directly with natural persons shall ensure that natural persons are informed that they are interacting with an AI system, unless this is obvious from the circumstances and the context of use.”
In plain terms: if a user could reasonably think they are talking to a human, you must tell them they are not. This applies to:
- •Customer service chatbots
- •AI-powered live chat widgets
- •Automated email response systems
- •Any AI system that interacts directly with users
Our AI Disclosure Scanner checks your website automatically for each of these transparency requirements.
The exemption is narrow — “obvious from circumstances” means something like a clearly labeled robot interface, not just a bot name like “Aria” or “Max.”
When Did This Become Enforceable?
August 2, 2026 is the enforcement date for Article 50 transparency obligations. Key dates:
| Date | Obligation |
|---|---|
| August 1, 2024 | EU AI Act enters into force |
| February 2, 2025 | Prohibitions on high-risk AI practices begin |
| August 2, 2026 | Chatbot transparency rules become enforceable |
| August 2, 2027 | Additional high-risk AI system requirements |
Real Enforcement Cases — What Happened to Companies That Failed
Regulators have already taken action against companies for AI transparency failures under existing laws, before the EU AI Act was even enforceable:
| Company | Regulator | Action | Year |
|---|---|---|---|
| Snap Inc. (My AI) | UK ICO | Enforcement Notice | 2023 |
| DoNotPay | US FTC | $193,000 fine + cease order | 2025 |
| Replika (Luca Inc.) | Italian Garante | Administrative fine | 2025 |
| Unnamed Bank | Berlin DPA | €300,000 fine | 2023 |
These cases happened under GDPR and FTC rules — frameworks with lower maximum penalties than the EU AI Act. Under the AI Act, fines for transparency violations can reach €15 million or 3% of global annual turnover, whichever is higher.
US State Chatbot Disclosure Laws in 2025–2026
The EU is not alone. Six US states have passed or are enacting chatbot disclosure requirements:
| State | Law | Effective | Requirement |
|---|---|---|---|
| California | SB 243 | Oct 13, 2025 | Clear notice of AI chatbot interaction |
| Colorado | SB24-205 | Feb 1, 2026 | Disclosure unless obvious to reasonable person |
| Maine | Title 10 §1500-DD | Jul 1, 2025 | No misleading users into thinking they talk to a human |
| New York | S8874 | Expected 2026 | Disclosure at point of interaction |
| South Carolina | Bill 5138 | Pending 2026 | Clear and conspicuous notice required |
| Texas | HB149 | Jan 1, 2026 | AI disclosure for health care and broader business use |
What Does a Compliant Chatbot Disclosure Look Like?
Non-compliant patterns regulators have flagged:
How to Check If Your Website Is Compliant
If you answered no to any of these, your website has a disclosure gap. Run a free automated scan on SiteProof AI — our scanner checks your website against EU AI Act Article 50, GDPR, CCPA, and FTC requirements and gives you a scored report with specific fixes.
For a full breakdown of why US-based websites are in scope, see our guide on does the EU AI Act apply to US companies.
Also see: EU AI Act small business guide.
Frequently Asked Questions
Does a simple chat widget count as a chatbot under the EU AI Act?
Yes — if it uses AI to generate responses (including LLM-based assistants, rule-based bots that can pass as human, or any system simulating human conversation), it falls under Article 50(1) disclosure requirements.
Where exactly must the chatbot disclosure appear?
EU AI Act Article 50 requires disclosure 'at the latest at the beginning of the first interaction.' Best practice is to display it in the chat window header, first bot message, or a launch screen before the conversation starts.
Does a chatbot disclosure in the terms of service comply?
No. Regulators have clarified that disclosures buried in terms of service or privacy policies do not meet the 'clear and conspicuous' standard. The disclosure must be in the interface where the user interacts with the chatbot.
My chatbot is clearly branded as a bot. Do I still need a disclosure?
Yes. Even if your chatbot has a robot name or icon, an explicit text disclosure is still required under Article 50. Visual cues alone do not satisfy the regulation.
When does EU AI Act Article 50 become enforceable?
August 2, 2026. That is the date when transparency obligations for limited-risk AI systems — including chatbots — become fully enforceable across all EU member states.
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