Law explained

“But it's obvious it's a bot” — examining the exemption before you rely on it

Article 50(1) doesn’t require a disclosure where interacting with AI is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and context of use.

Why the bar is higher than you think

The benchmark is your average customer in context — not a tech-savvy founder. Modern chat interfaces are deliberately human-like: typing indicators, first names, natural language. The better your bot, the weaker your “obvious” argument. Voice AI on a phone line is the extreme case: callers default to assuming human.

When the exemption is genuinely solid

An interface labeled “AI assistant” in the header (which is… a disclosure), a plainly robotic menu-bot (“Press 1 / type ORDER”), an AI feature inside a tool marketed as AI.

The economics of the argument

Relying on the exemption saves you a one-line notice and buys you a debatable legal position. Adding the notice costs nearly nothing, reassures customers (people dislike being deceived by bots far more than they dislike bots), and ends the question. That’s the whole analysis. We built a widget so the notice is also the best-looking element on the page.

Sources are cited in place; official text: Regulation (EU) 2024/1689. This guide is a technical explanation, not legal advice.