EU AI Act Article 50 for AI agents that email, call and post for you
Since 2 August 2026, people must be told when they deal directly with an AI system, unless it is obvious. Most guidance pictures a chat window. Agents that email, call or post for you raise the same duty in new places. The information must reach people "at the latest at the time of the first interaction or exposure".
The core text
Article 50(1): "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."
Article 50(5): "The information referred to in paragraphs 1 to 4 shall be provided to the natural persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure."
What may apply, by what the agent does
| What the agent does | Part that may apply | Who must act | From |
|---|---|---|---|
| Chats with customers or staff | Article 50(1) | Provider | 2 August 2026 |
| Writes emails or messages to people for you | Article 50(1) may apply. The Article does not say whether an email counts as interacting directly. | Provider | 2 August 2026 |
| Places or answers phone calls | Article 50(1), with the timing in 50(5): at the first interaction | Provider | 2 August 2026 |
| Publishes text "with the purpose of informing the public on matters of public interest" | Article 50(4), second subparagraph, unless the text "has undergone a process of human review or editorial control" and someone "holds editorial responsibility" | Deployer | 2 August 2026 |
| Generates synthetic audio, image, video or text | Article 50(2): outputs "marked in a machine-readable format and detectable as artificially generated or manipulated" | Provider | 2 August 2026; 2 December 2026 for systems placed on the market before 2 August 2026 (Art. 111(4)) |
| Reads emotions or sorts people by biometric data, where that is not banned | Article 50(3): tell the people exposed to it | Deployer | 2 August 2026 |
Questions to settle before launch
- Does every channel your agent uses (chat, email, voice, posts) tell people it is AI at the first contact?
- Is it really "obvious" to the person, or only to you?
- Who is the provider and who is the deployer for each channel?
Where Astroware fits: HaloGuard EU is built to block output that hides that it is AI.
Sources:
- Regulation (EU) 2024/1689, Articles 50 and 111: http://data.europa.eu/eli/reg/2024/1689/oj
- Regulation (EU) 2026/1744: http://data.europa.eu/eli/reg/2026/1744/oj
As of 28 October 2026. This page explains the text of the Act. It is not legal advice.