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EU AI Act transparency requirements for online shops — what applies now

· AI Act · compliance · transparency · e-commerce

Article 50 of the EU AI Act (Regulation 2024/1689) entered into force on 2 August 2026. If your online shop deploys a chatbot, an AI-powered recommendation engine, or any system that interacts with customers without making the AI nature obvious, you now have a disclosure obligation.

What Article 50 actually requires

Article 50 covers four scenarios. The two that apply to most e-commerce shops are:

Article 50(1) — chatbots and AI interaction. When a customer communicates with an AI system that is designed to hold a conversation — a support chatbot, a product assistant, a virtual stylist — you must inform them that they are talking to an AI, not a human. The disclosure must happen at the start of the interaction, not buried in a footer.

Article 50(5) — accessibility of the disclosure itself. The transparency notice must meet the same accessibility requirements as the rest of the service. An AI disclaimer that a screen reader cannot announce breaches the AI Act and the European Accessibility Act simultaneously.

What is explicitly out of scope

Article 50(4) contains a carve-out that matters for e-commerce: AI-generated product descriptions, alt text, and similar content are exempt from mandatory disclosure when a human has reviewed the output and taken editorial responsibility for it. The exemption applies to the content itself — the chatbot still needs a disclosure, even if the chatbot replies were partially drafted with AI.

Article 50(2) — the machine-readable marking of AI-generated images — binds model providers, not shops that use those models. You are not required to add C2PA provenance metadata to product images unless you operate the model that generated them.

Which AI systems in your shop fall under Article 50(1)

Go through every customer-facing touchpoint and ask whether a customer could reasonably believe they are talking to a person:

  • Live chat widgets powered by a large language model (Tidio AI, Intercom Fin, Zendesk AI, ChatGPT integrations)
  • AI-generated email responses sent under a human name
  • Automated WhatsApp or Messenger bots
  • Voice assistants on product pages

Standard product recommendations (the "customers also bought" block) and automated pricing algorithms are not covered by Article 50(1) — they do not simulate human conversation.

The fine exposure

Article 99(6) caps fines for small and medium enterprises at the lower of €15 million or 3 % of global annual turnover. There is no microenterprise exemption for Article 50 — the size carve-out that exists in the EAA does not apply here.

Three steps to cover Article 50 today

  1. Audit every AI touchpoint. List every system that interacts with customers. For each one, decide whether a customer could mistake it for a human.

  2. Add a disclosure at the start of AI interactions. It does not need to be long. "You are chatting with an AI assistant" at the opening message satisfies Article 50(1). The text must be readable by assistive technologies.

  3. Document what you found and what you changed. The AI Act is enforced by national market surveillance authorities. A written record showing you assessed the obligation and acted on it is the difference between a warning and a fine.

Check your shop in two minutes

Run a free EU AI Act readiness check on your storefront. The scan looks at every page frame — including chat widgets loaded in cross-origin iframes — and tells you which transparency requirements are missing and what to do about them.