Glossary
AI disclosure requirement
Under Article 50(1) of the EU AI Act, people must be informed that they are interacting with an AI system unless this is obvious.
The duty falls on the providers of AI systems intended to interact directly with people: they have to design their systems so that the persons concerned are informed. The information must be given clearly and distinguishably at the latest at the time of the first interaction. Under Article 113 of the regulation, Article 50(1) applies from 2 August 2026. This is EU law; other jurisdictions have their own rules.
For phone calls this means in practice: the assistant says at the beginning that an AI is speaking. A human-sounding voice without a notice does not meet the requirement. The regulation also covers the marking of artificially generated audio content in Article 50(2). Further rules may apply alongside it, for example from data protection and competition law.
In practice
In a call, one short, plain sentence in the greeting is enough, for instance: “Good morning, this is the practice’s digital assistant, I am an AI.” The notice belongs at the beginning and not in the middle of the conversation or in the privacy policy. It should be given in the caller’s language and on outgoing calls too. A phrase such as “virtual colleague” without an unambiguous term leaves open whether a person is speaking. Which wording is sufficient in your case is, when in doubt, for a legal professional to judge.
An example
An estate agency has an assistant take viewing requests; it has a first name and sounds very natural. In the first version it answers with “Hello, this is Lena from the agency”. During the trial, callers only realise after a few sentences that no person is on the line, and feel deceived. The agency changes the greeting to “This is Lena, the agency’s AI assistant”. Now callers know from the first sentence who they are talking to.
A common misunderstanding
Some regard the notice as a drawback to be kept as inconspicuous as possible. But mumbling it, placing it after a long greeting or mentioning it only on the website risks that it does not count as clear and unambiguous. Another misconception is that the duty lapses as soon as the voice sounds artificial. Do not rely on that. One unambiguous sentence at the start takes two seconds and creates clarity for both sides.
At Call0
Call0 plays an AI notice at the start of a call. Under the terms, customers may not disable or bypass this notice.
Source: Regulation (EU) 2024/1689 (EU AI Act), Art. 50 and Art. 113
This entry explains the general principle, with a focus on German and EU law, and is not legal advice. For your case, the text of the law and the advice of a qualified professional apply.
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As of: 12 October 2026