EU AI Act: your chatbot has to say it is AI - and 2 December ends the marking grace period

Since 2 August 2026, Article 50 of the EU AI Act applies to any product that interacts with EU users:

• Chatbots must disclose they are AI - before or during the first interaction.
• AI-generated text, image, audio and video must carry a machine-readable mark.
• Deepfakes need a visible disclosure label.

If your system was on the market before 2 August, the grace period for the marking duty ends 2 December 2026. Fines run up to 3% of global turnover.

Who is in scope

SaaS founders shipping chat features, AI content tools, onboarding bots, support agents - anything an EU user might interact with. "We have no EU office" does not exempt you: the Act follows the users, not your HQ.

The practical checklist

1. Map every AI feature that interacts with users (chat, content generation, voice, avatars).
2. Add disclosure copy at the right point - first interaction for chatbots, visible labels for deepfakes.
3. Mark generated content machine-readably (metadata or watermark; the technical standard is still being finalised, so document your interim approach).
4. Keep records of what is disclosed where - regulators ask for evidence, not intentions.

We turned this into a $29 template pack (obligation map, disclosure wording you can adapt, marking checklist). There is a free obligation checker on the page if you want to see where you stand first: https://shuttlewright-ai-transparency-pack.pillar-3a8.workers.dev/

Templates, not legal advice.