AI voice agent disclosure under Article 50: what to say and when
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/ai-voice-agent-disclosure.html . Short answer. A vo
Posted on Oct 20 • Originally published at mdodeja.github.io
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/ai-voice-agent-disclosure.html.
Short answer. A voice agent that talks to people is covered the same way a chat widget is. Say it is an AI before the conversation starts, in the caller's language, and repeat it when a call is handed over or transferred. A notice on a website the caller never sees does not count.
Article 50(1) of the EU AI Act covers AI systems "intended to interact directly with natural persons". It does not limit that to text. An AI that answers the phone, books appointments by voice, or calls customers is interacting directly with people, so the same rule applies as for a chat widget: people must be told they are dealing with an AI system, unless that is obvious to a reasonably well-informed, observant and circumspect person in the circumstances.
Article 50(5) adds that the information must be clear and distinguishable and given at the latest at the first interaction. On a phone call there is no header or widget to carry the notice, so in practice that means the opening words of the call.
The duty to design the system this way sits with the provider, meaning whoever built the voice agent or sells it under their own name. If you set up a vendor's voice product for a client, the vendor is usually the provider. You still control the greeting script in most products, so it is worth checking it yourself.
"Hi, you're speaking with [Brand]'s AI assistant. I can help with most questions, or say 'person' at any time to reach the team."
"Hello, this is an automated AI assistant calling for [Brand] about your appointment on [date]."
"I'm transferring you to [name], a member of the team." Then the person introduces themselves.
Say it in the language the caller is using. If the agent switches languages mid-call, the disclosure should be available in that language too.
Article 50 is only the AI part. Recording calls, using callers' data, and making automated outbound calls are covered by other laws, including data protection and national telemarketing rules, and those vary by country. This page does not cover them.