Making a chatbot's AI disclosure accessible: what Article 50(5) asks for

A developer published a guide interpreting Article 50(5) of the EU AI Act, which requires AI disclosures in chatbots to conform to applicable accessibility requirements. The guide argues the Act does not define those requirements but points elsewhere to the European Accessibility Act and the Web Accessibility Directive, whose harmonised standard EN 301 549 follows WCAG 2.1 level AA. It recommends that an accessible disclosure be real text in the chat transcript, announced to screen readers, with sufficient contrast, and not hidden behind an icon or hover.

This guide was drafted by an AI agent from the primary sources linked at the bottom, and has not been reviewed by a lawyer. It is general information, not legal advice. The original is at https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/accessible-chatbot-ai-disclosure.html https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/accessible-chatbot-ai-disclosure.html . Short answer. Article 50 5 says the AI disclosure "shall conform to the applicable accessibility requirements". The Act does not list them, but the accessibility laws it names elsewhere are the European Accessibility Act for e-commerce and other covered services and the Web Accessibility Directive for public bodies . Microenterprises providing services are outside the European Accessibility Act. In practice, an accessible disclosure is real text in the chat transcript, announced to screen readers, with enough contrast, and not hidden behind an icon or a hover. Article 50 5 covers every disclosure in Article 50, chatbots included: "The information referred to in paragraphs 1 to 4 shall be provided to the natural persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure. The information shall conform to the applicable accessibility requirements." "Applicable" is not defined in Article 50. Where the Act deals with accessibility for high-risk systems, Article 16 l points to two directives: the Web Accessibility Directive EU 2016/2102 and the European Accessibility Act, Directive EU 2019/882. Reading Article 50 5 the same way, the disclosure has to meet whichever of those already applies to the website or app the chatbot sits on. That is a reading, not settled law; the Commission's guidelines may say more. | Where the chatbot runs | Accessibility rule that already applies | Effect on the AI disclosure | |---|---|---| | Public-sector website or app | Web Accessibility Directive | Disclosure must meet the same standard as the rest of the site | | Online shop, banking, transport ticketing or another service covered by the European Accessibility Act applies since 28 June 2025 | European Accessibility Act | Same | | Service run by a microenterprise fewer than 10 staff and turnover or balance sheet of no more than EUR 2 million | Not the European Accessibility Act: its requirements do not apply to microenterprises providing services, per Ireland's CCPC | No specific accessibility law, but the disclosure still has to be "clear and distinguishable" | | B2B site not in a covered sector | Often none | Same as above | National laws implementing the two directives add detail and differ by country. Germany's BFSG is one example. For agencies, the useful point is that the disclosure is part of the chat interface. If a client's site has to meet the European Accessibility Act, an inaccessible chat widget is already a problem, and the AI line inherits that. The harmonised European standard for these directives is EN 301 549, whose web clauses follow WCAG 2.1 level AA. These are the WCAG success criteria a chatbot disclosure most often fails: Plain wording helps everyone: "I'm an AI assistant, not a person" is easier to follow than "This conversational agent is powered by generative artificial intelligence". The disclosure wording guide https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/chatbot-ai-disclosure-wording.html has examples.