The assistant on your page has to say it is not a person

There is an obligation that has been in force for a month, affects thousands of sites, and almost nobody has heard about it. It does not come with a press release, because it is small. So small it fits in one sentence: if you have a conversational assistant on your page, the visitor has to know they are not talking to a person.

That is the whole thing. And yet, open ten sites with a chat bubble and count how many say so. You will get tired before you find three.

Where this is written, and since when

In Article 50 of Regulation (EU) 2024/1689, the one everyone knows as the AI Act. Article 113 sets the general application date at 02/08/2026, with specific exceptions that fall earlier or later. Article 50 is not one of them. So it has been running since 02/08/2026, which is to say since most of us were somewhere with sand.

Let me interrupt you here, because I know what you heard. “Didn’t they postpone all of it?”

Not all of it. Regulation (EU) 2026/1744 of 08/07/2026, the Digital Omnibus, did move a great deal: stand alone high risk systems to 02/12/2027, those embedded in products to 02/08/2028, regulatory sandboxes to 02/08/2027. On transparency it granted nothing. It did the opposite: according to the Council’s announcement, it cut the grace period for technical marking solutions for artificially generated content from six months to three, with a deadline of 02/12/2026.

So the 02/12/2026 date doing the rounds is not a postponement. It is a second, tighter deadline for something else. The first thing is already live.

Two different obligations, and people mix them up

Article 50 does not say one thing, it says two, and it speaks to different people.

The first paragraph covers systems that interact directly with people. It asks that they be designed and developed so that the person is informed they are interacting with an AI system. With one sensible exception: where this is already obvious to a reasonably well informed and observant person. If the button says “Ask our assistant”, nobody will get far claiming they were fooled.

The fourth paragraph covers publication. Anyone publishing image, audio or video content that constitutes a deep fake has to disclose it. And anyone publishing text that is generated or manipulated for the purpose of informing the public on matters of public interest, likewise.

But look at the exception in the fourth paragraph, because it is half the substance: it does not apply where the content has undergone human editorial review and a natural or legal person holds editorial responsibility for the publication. There is a second exception too, for evidently artistic, satirical or fictional work, where a discreet disclosure that does not spoil the work is enough.

In plain words. An article a program produced, that a person read, corrected, signed with their name and owned, needs no marking. Text that was produced in bulk, touched by nobody, and published to inform the public, does. The line is not the program. The line is the human who takes responsibility.

And now the question you were about to ask: who does this fall on?

You thought right. The first paragraph addresses providers of the system. The fourth addresses deployers, meaning whoever puts it to use.

So if you bought a ready made chat widget and dropped it on your site, the design obligation is not, on the letter of the text, yours. It belongs to whoever built it.

Except that the notice, if it is missing, will be missing from your page. The visitor does not know who wrote the widget and does not care. Which makes the practical question not a legal one but a single question to your supplier: does the system tell the user, or not? If not, it goes in from your side. Ten minutes of work.

And because the text of the Regulation is a text and your case is yours: this is not legal advice. I am showing you where what is written, with the links beside it, so you know what to ask your lawyer if it comes to that.

What our own assistant did, and what it did not do until I wrote this

It would be awkward to write about transparency and not look at what my own site does. I looked. It was not doing it well enough.

The assistant on mslogic.gr was labelled “Smart assistant” at the bottom of the panel, and its opening line said it was the MS-Logic assistant. Nowhere did it say it is not a person. And “assistant”, if you think about it, could perfectly well be an employee.

We would most likely have passed under the obvious exception. Most likely. And “most likely” is a poor place to stand when you are writing something that tells other people what to do.

So the opening line changed. It now says:

“Hello! I am the MS-Logic smart assistant. A program, let us be clear, but I know the job.”

Five words in the middle of a sentence. Not one of them is a legal term, not one of them says “AI”, and not one of them leaves room for a misunderstanding. What was already there stayed: “Smart assistant” at the bottom of the panel, and the note under the details form that conversations are recorded to improve the service, with a link to the Privacy Policy.

To be exact: the Regulation was the prompt. The reason is something else, and I would keep it even if the law changed tomorrow. A visitor who thinks they are talking to a person and then works out they were talking to a program does not get angry at the program. They get angry at you. And they are right to.

The same goes for the writing. Every article here carries an author name and a date, and every number we print has the link to its source underneath. That is not marking, it is the same idea through a different door: the reader should know who is speaking to them.

What I would tell a client today

Open your site in a private window and behave like a stranger. If a chat bubble appears, see whether the first thing you read tells you who you are talking to. If you have published text no human ever read, put a human on it, because it shows anyway.

And do not be afraid of the word. “You are talking to our assistant” has never driven a customer away. “I thought I was talking to a person” has driven off plenty.

If you want to go through what is on your site today and what it says, get in touch. It is not a big job. It is the kind that is better done before somebody asks you for it.