Classified examples · Customers and content · Po polsku
A vendor's AI chatbot answers customers on our website
Transparency (Article 50)Deployer
The company switches on an AI chatbot from its customer-service platform. It answers customer questions on the website.
How we classify it
- The chatbot is the vendor's AI system; the company deploys it.
- Customer service is not listed in Annex III and is not prohibited: not high-risk.
- It interacts directly with people, so Article 50(1) applies: people must be told they are dealing with AI, clearly and at the latest at the first interaction, unless it is obvious. The duty is on the provider's design; the company must make sure the disclosure is switched on and visible.
- Result: transparency obligations (Article 50), in force since 2 August 2026.
What applies now
- An AI disclosure in the first message, and a way to reach a person
- GDPR information for the chat, and limits on what personal data the bot asks for
- Contract terms: vendor support for transparency, incident notice, no training on your conversations
- Register entry and owner; test the disclosure after every configuration change
What would change the answer
- If you present the chatbot as your own product built on a model you chose, you may be its provider (see 'We build a chatbot on a model API')
- If the bot decides on access to essential services or credit, the use can become high-risk (Annex III point 5)
Evidence to keep
- Screenshot of the first message, dated
- Transparency checklist
- Vendor questionnaire and contract
In the AI Compliance Kit: 05Transparency Checklist and Disclosure Texts · 03AI System Inventory · 07Vendor Due Diligence Questionnaire · 11Contract Clauses.
Dates and sources
- Transparency obligations, Article 50: 2 August 2026
- AI literacy duty, Article 4: 2 February 2025
Legal basis: AI Act art. 50(1), 50(5); GDPR art. 13.
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