CLAIM-2026-07-30-03
Article 50(1) requires providers of AI systems that interact directly with natural persons to make the AI nature known, where the interaction is a genuine two-way exchange. The exception for cases where it is obvious the person is interacting with an AI is to be interpreted in a restrictive manner, assessed against a reasonably well-informed, circumspect and observant average person.
Why it matters
Most teams assume a developer audience makes the AI nature obvious and skip the disclosure. The Commission says that exception is to be read restrictively and judged against an objective average person, not against your user base.
Sources
- europeancom2026faq
- stibbe2026transpare