I originally published this on disclosekit.dev — I'm building tooling for this deadline and the research surprised me enough to share.
June 2026 · 5 min read
Short answer: if your chatbot talks to people in the EU, probably yes. From August 2, 2026, Article 50(1) of the AI Act requires you to tell users they are interacting with an AI system. Not in your terms of service. At the start of the conversation, where they can actually see it.
The test is where your users are, not where you are
A Delaware C-corp with a support bot used by customers in Berlin is covered. A French SaaS whose bot only serves a US audience is, for this rule, not. The AI Act follows the people affected, the same extraterritorial logic GDPR uses. If you can't rule out EU users, the safe assumption is that you have them.












