KI-Transparenz-Check

How should an AI disclosure in a chatbot be worded?

Short answer

The regulation prescribes no wording. It requires that the person interacting understands they are dealing with an AI system, clearly and distinguishably. In practice: use the word "AI", because anything weaker is left to interpretation.

Why that is

Paragraph 1 sets an outcome — the person is informed — and leaves the sentence to you. Our check P2 measures it in two grades, and the split is the whole argument. Wording that names artificial intelligence outright ("AI assistant", "artificial intelligence", and the German equivalents) counts as a strong disclosure. Wording like "bot", "virtual assistant" or "automated reply" counts as weak and is reported separately: those words say a human may not be answering, not that an AI is. Whether that suffices in a given case is for courts to decide, not for us — which is why the weak grade is reported as "needs review" rather than as a violation. If you would rather not have the argument at all, name the AI.

This is measured in check point P2 — AI disclosure inside the chat (Art. 50 Abs. 1).

What this means in practice

Put the disclosure in the bot's opening message, as its own sentence, in the language the user is being addressed in. Three pieces carry such a sentence: what is answering (the AI, named), what it is for, and how to reach a human. The third is not required by paragraph 1, but it is the difference between a notice that satisfies the rule and one that does not irritate the visitor. Avoid hiding the AI behind a first name — a bot that introduces itself only as "Anna" works against the purpose of the provision.

Check it on your own page

P2 opens the chat window, reads the visible text including embedded frames, and reports which grade it found — or that it found no disclosure at all. If the window cannot be opened automatically, we say so instead of claiming a violation.

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Legal note

This page provides general information on the EU AI Act — it is not legal advice and not a legal assessment of your individual situation (cf. German Federal Court of Justice, judgment of 9 September 2021, I ZR 113/20). It does not replace review by a lawyer. When in doubt, consult one.

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