How to disclose an AI chatbot on your store (Article 50)

When you need to disclose a chatbot

The trigger is interaction. If a shopper types to an AI system and it answers, they are interacting with AI, and they should know it. This covers AI chatbots, shopping assistants, AI-driven live chat, and any widget where a machine is generating the replies. It does not cover a plain contact form, a canned FAQ page, or a live chat that is always staffed by real people, because in those cases there is no AI system standing in for a human.

Under Article 50 the duty to build this disclosure into the chatbot sits with the provider that made it. You are usually the deployer, so the safe, practical move is to add your own visible notice rather than assume the tool already handles it. It costs you almost nothing and removes the doubt.

Example notice wording

Good notices are short, plain, and honest. They name the AI, say what it does, and set the expectation that a human is available. Here are three you can adapt:

Avoid vague phrasing like smart assistant or virtual helper on its own. Those words do not tell a shopper the replies are machine generated. If the tool can hand off to a human, say so, because that reassures shoppers rather than putting them off.

Where to place the notice

Placement is where most disclosures fail. The notice has to be where the shopper actually looks, at the moment they are about to talk to the AI. In order of preference:

• In the chat window header. A persistent label at the top of the chat panel is visible the whole time the conversation is open. This is the strongest placement.
• As the opening message. The AI introduces itself as AI before the shopper starts typing. Simple and clear, though it scrolls away as the chat grows, so pair it with a header label where you can.
• On the launcher, for context. A small note near the chat bubble helps, but on its own it is easy to miss, so treat it as a supplement, not the main disclosure.

The disclosure should not live only in your terms of service or a privacy page. A notice a shopper has to go hunting for is not a notice they will see, and being seen is the entire point.

Translate it for the markets you sell in

A disclosure only works if the shopper understands it. If you sell into several EU markets, the notice should appear in the languages those shoppers read, not in a single default language. This is easy to overlook when a chat tool ships in English only. Aclara auto-translates the notice into 24 EU languages so the shopper sees it in a language they actually understand.

Common mistakes to avoid

• Hiding the disclosure in a policy page instead of showing it in the chat itself.
• Using soft words (smart helper, virtual concierge) that never actually say AI.
• Showing the notice once at launch, then losing it as the conversation scrolls, with nothing persistent to fall back on.
• Leaving the notice in one language while selling across several EU markets.
• Letting a theme update break or hide the widget, so the notice silently stops showing. Verify it still renders after changes.

How Aclara handles it

Aclara adds an AI chat notice to your theme as an app embed, translates it into the EU languages you need, then reads your live theme to confirm the notice is actually rendering. If a theme change hides it, you can see that and fix it, and Aclara keeps a dated record of what was disclosed and when. It uses a single read-only theme permission and stores no customer data.

Frequently asked questions

Do I legally have to add a chatbot notice as the store owner?

The design duty sits with the chatbot provider. As the deployer, adding your own clear notice is the simplest, safest way to make sure the disclosure actually reaches your shoppers.

What should an AI chat notice say?

Keep it short and honest, for example: You are chatting with an AI assistant. It can help with orders and product questions and will pass you to a human when needed.

Where does the notice belong?

At the point of conversation: in the chat window header or as the first message, so the shopper sees it before or as they start typing, not buried in a policy page.

Does the notice need translating?

It should be understandable to the shopper who sees it, so translate it into the EU languages you sell in rather than leaving it in one language only.