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AI agents under Article 50: disclose the AI — and whose agent it is

Current to 26 August 2026 · updates land in the changelog.

Agents did not slip through the AI Act. The final Article 50 guidelines (20 July 2026) state that AI agents fall under the Article 50(1) disclosure duty — and they go further than the chatbot baseline: an agent must disclose its artificial nature and the person on whose behalf it is acting.

What that means in practice

An agent that emails, books, negotiates or calls on a user's behalf is interacting with other natural persons — and those people are the ones Article 50(1) protects. The guidelines cover multi-agent setups too, and they close the branding loophole explicitly: generic “assistant” naming is insufficient. “Alex from scheduling” does not satisfy a duty whose point is that the counterparty knows they are dealing with software acting for someone.

Both sides of the interaction

Agent products typically face the duty twice: the user commanding the agent (your direct user — informed at first interaction) and the third parties the agent contacts (informed by the agent, in the interaction itself). The second leg is the one product teams miss, because the disclosure has to travel inside the agent's output — its emails, its calls, its chat messages.

The adjacent duties

Agents that generate content inherit the Article 50(2) marking duty on that content, and voice agents sit in the same frame as voice AI generally. Where an agent operates purely inside a company — never exposed externally — the narrow three-condition B2B carve-out may apply.

Related guides

Quick answers

Do AI agents have to disclose they are AI in the EU?
Yes — the final Article 50 guidelines place AI agents under Article 50(1), applying since 2 August 2026, including in multi-agent configurations.
Must an agent say who it is acting for?
Per the final guidelines, yes: agents must disclose their artificial nature and the person on whose behalf they act. Generic 'assistant' naming is expressly insufficient.
Ship the disclosures before enforcement finds the gap.

The AI Act Article 50 Kit: the disclosure copy library (English + 中文), the marking implementation guide with survival-test protocol, deepfake and text-labeling walkthroughs, obviousness and scope memos, the evidence log, the Code of Practice accession path — built from the regulation and the final guidelines, with pinpoint citations.

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General information only — not legal advice, and no clearance opinions. Sources are Regulation (EU) 2024/1689 (Articles 50 and 99), Regulation (EU) 2026/1744, the Commission's final Article 50 guidelines of 20 July 2026 (non-binding) and our audited kit research. Marking-technology status changes fast: treat vendor announcements as live only once verified. © 2026 Kilde.

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