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Knowledge base · AI in HR

Does our recruitment chatbot have to say that candidates are talking to AI?

Yes, since 2 August 2026 a chatbot must be designed so that people know they are communicating with AI, unless that is already obvious. That duty lies with the provider of the chatbot. If you built the chatbot yourself, including on a third party's model, and deploy it under your own name, you are the provider.

In force now (since 2 August 2026)Trusq editorial · checked against the official textLast verified:

Next step: Take the Article 50 check

The duty

Providers ensure that AI systems intended to interact directly with people are designed so that those people know they are interacting with an AI system, unless this is obvious to a reasonably well-informed, observant person [1]. This duty has applied since 2 August 2026 [2].

Who bears the duty

Article 50(1) is addressed to the provider. A provider is anyone who develops an AI system, or has one developed, and puts it into service under their own name or trademark [3]. If you use a supplier's chatbot, Article 50(1) does not put that duty on you, but do check that the chatbot gives the notice. If you build a chatbot yourself on a third party's model and put it on your jobs site, you are the provider and the notice is your duty.

What Trusq bases this on

These released rules are in Trusq and are read again with every publication; if a rule changes, this page changes with it.

  • Chatbot disclosure AI Act 50
  • Who carries Art. 50(1) and (2) for this system AI Act 3, AI Act 50
  • Risk of becoming a provider AI Act 3, AI Act 25

Sources

  1. [1] AI Act Art. 50(1) (AI Act, Regulation (EU) 2024/1689). The provider ensures that an AI system intended to interact directly with people is designed so that they know they are interacting with AI, unless this is obvious to a reasonably well-informed, observant person.
    Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use.
    Source, retrieved on 2 October 2026.
  2. [2] AI Act Art. 113, second paragraph (AI Act, Regulation (EU) 2024/1689). The general date of application of the AI Act is 2 August 2026; the transparency duties of Article 50 fall under it.
    It shall apply from 2 August 2026.
    Source, retrieved on 2 October 2026.
  3. [3] AI Act Art. 3(3) (AI Act, Regulation (EU) 2024/1689). A provider is anyone who develops an AI system, or has one developed, and places it on the market or puts it into service under their own name or trademark.
    ‘provider’ means a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge;
    Source, retrieved on 2 October 2026.

Related questions

Do we have to label job ads or recruitment images made with AI as AI content?We are buying an AI tool for HR. Are we then the provider or the deployer?What do we, as an SME, have to arrange now if we use AI in HR?

Next step

Five questions about chatbots and AI-generated content. You see at once which transparency duties under Article 50 may apply, with the legal text and the source. You do not have to enter any data.

Take the Article 50 check

Looking for a specialist? We will look with you for a suitable specialist; mediation is not guaranteed.

This page gives general information based on the text of the law. It is not legal advice for your situation.