GuidanceGuidancev1.0.0

Disclosure at the latest at first interaction, and again for every new person

The notice that a person is dealing with an AI system must be given at the latest at the time of the first interaction. That moment applies per natural person, not once per system.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

This object has an address of its own that is never renamed or reused. Store the identifier in your own file, not the title or the link.

Identifier: praxikon:eu:ai-act:guidance:guidance-article-50-disclosure-timing
Payload hash (sha256): 1d84d58420f8a24a1d13d7b31bea51d92ef06ea18d81146ab84a1a1964afde98

Citation line

Praxikon, "Disclosure at the latest at first interaction, and again for every new person", praxikon:eu:ai-act:guidance:guidance-article-50-disclosure-timing@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z, sha256 1d84d58420f8a24a1d13d7b31bea51d92ef06ea18d81146ab84a1a1964afde98

Version: 1.0.0
Legal time (effective_at): 8 August 2026
Knowledge time (known_at): 8 August 2026
Closed on: Not closed
Topics: guidance

Review status: Placed against the official source (8 August 2026). Next check due by 4 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

The obligation this hangs off

1 of 1 shown

The object belongs to this obligation. The source line it hangs off sits there.

Source
Official fact on this object, with its locator.
- Guidelines on Article 50
  Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 3.1.2 points (33) and (40), and Section 7.2 point (143)
  praxikon:eu:ai-act:source:commission-article-50-guidelines
  Open official source
Via
- Condition | allApplies to providers of AI systems intended to interact directly with natural persons, and through the horizontal requirements of Article 50(5) to all notices under Article 50(1) to (4).
- ExceptionThe information obligation falls away if the interaction is obvious to a reasonably well-informed, observant and circumspect person, or if the system is authorised by law to detect, prevent, investigate or prosecute criminal offences, unless the system is available to the public to report a criminal offence.
As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.
Consequence
- ObligationArticle 50: transparency
  praxikon:eu:ai-act:obligation:article-50-transparency

What this object is about

2 of 2 shown

The object is about this role. Undifferentiated: it does not follow that the duty rests on this role.

Source
Official fact on this object, with its locator.
- Guidelines on Article 50
  Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 3.1.2 points (33) and (40), and Section 7.2 point (143)
  praxikon:eu:ai-act:source:commission-article-50-guidelines
  Open official source
Via
- Condition | allApplies to providers of AI systems intended to interact directly with natural persons, and through the horizontal requirements of Article 50(5) to all notices under Article 50(1) to (4).
- ExceptionThe information obligation falls away if the interaction is obvious to a reasonably well-informed, observant and circumspect person, or if the system is authorised by law to detect, prevent, investigate or prosecute criminal offences, unless the system is available to the public to report a criminal offence.
As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.
Consequence
- ActorDeployer
  praxikon:eu:ai-act:actor:deployer
- ActorProvider of an AI system
  praxikon:eu:ai-act:actor:provider

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

The final Commission guidelines of 20 July 2026 (C(2026) 5054 final) state in point (33) that the notification mechanism must be embedded in the design of the system and that the notice must be provided during operation of the system and at the latest at the time of the first interaction with the natural person, as required by Article 50(5). Point (143) clarifies that 'first interaction or exposure' refers not only to the first person who encounters the system, but also to any subsequent first interaction with or exposure to the system by any other natural person. For an interactive system, the information must be provided at least once at the start of an interactive session. For content under Article 50(2) and (4), the information obligation applies to each output with respect to any natural person exposed to it. Point (40) adds that a single prominent notification before the first interaction is likely to suffice in most instances, but that in riskier contexts periodic reminders and context-aware disclosures are likely to be necessary, in particular for vulnerable persons, sustained or immersive interactions, financial, insurance, legal or health advice and complaints handling, and AI companions. That same point requires the system to be designed so that it always discloses where it is asked about its nature or the origin of the interaction, or where it can reasonably be assumed from the exchange that the person is likely to be misled or confused about the AI origin.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 3.1.2 points (33) and (40), and Section 7.2 point (143)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

The trap is the word 'first'. Many organisations read it as a one-off announcement when the chatbot launches, or as a line in a welcome email that every visitor is assumed to have seen. The guidelines read it as an obligation that arises anew for each natural person who encounters the system or its output for the first time. A second common error is assuming that a notice at the start of the session covers the whole customer journey. If the role of the system changes mid-session, or the interaction is long and concerns money, health or law, the Commission expects repetition. The third trap is letting the system dodge the question when a user directly asks whether they are speaking to a human. That is not permitted: the question must always be answered honestly, whatever notice was given earlier.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 3.1.2 points (33) and (40), and Section 7.2 point (143)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

Document for each customer contact channel at what moment the notice appears, and test it with a fresh session from a new device so you see what a first-time visitor sees rather than what a logged-in employee sees. Also build a hard rule into the system prompt or conversation logic that forces the system to confirm its AI origin as soon as it is asked or as soon as the user addresses it as a human. Finally, decide for your higher-risk channels, such as financial advice, claims handling, care and complaints, whether a single opening notice suffices or whether you need a persistent label or periodic reminders, and record that assessment in writing.
- Locator: Commission Guidelines C(2026) 5054 final, 20.7.2026, Section 3.1.2 points (33) and (40), and Section 7.2 point (143)praxikon:eu:ai-act:source:commission-article-50-guidelinesOpen official source

When this applies

1Applies to providers of AI systems intended to interact directly with natural persons, and through the horizontal requirements of Article 50(5) to all notices under Article 50(1) to (4).

When this does not apply

The information obligation falls away if the interaction is obvious to a reasonably well-informed, observant and circumspect person, or if the system is authorised by law to detect, prevent, investigate or prosecute criminal offences, unless the system is available to the public to report a criminal offence.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Disclosure at the latest at first interaction, and again for every new person",
praxikon:eu:ai-act:guidance:guidance-article-50-disclosure-timing@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0),
effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 1d84d58420f8a24a1d13d7b31bea51d92ef06ea18d81146ab84a1a1964afde98,
https://www.praxikon.com/en/verkenner/guidance/guidance-article-50-disclosure-timing
(https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aguidance%3Aguidance-article-50-disclosure-timing&effective_at=2026-08-08&known_at=2026-08-08&lang=en, accessed 2026-08-25)

Short form

praxikon:eu:ai-act:guidance:guidance-article-50-disclosure-timing@1.0.0 (sha256 1d84d584)

BibTeX

@misc{praxikon-eu-ai-act-guidance-guidance-article-50-disclosure-timing-1-0-0,
  author       = {{Praxikon}},
  title        = {Disclosure at the latest at first interaction, and again for every new person},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:guidance:guidance-article-50-disclosure-timing},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.1.0, schema 1.4.0},
  note         = {effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 1d84d58420f8a24a1d13d7b31bea51d92ef06ea18d81146ab84a1a1964afde98},
  url          = {https://www.praxikon.com/en/verkenner/guidance/guidance-article-50-disclosure-timing},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

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    "language": "en",
    "issued": {
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  }
]

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