EU AI Act Article 50: What a Voice Agent Must Tell Callers

Article 50 of the EU AI Act says an AI system that talks with people must be designed to tell them they are dealing with an AI, at the latest when the conversation starts. On a call, that means a clear spoken notice in the opening line. It has applied since 2 August 2026, unless the AI is obvious.

Key Takeaways

• Say it in the first line, out loud, before any question.
• Beeps or tones alone do not count as the notice.
• Switch off greeting interruption so callers hear the whole notice.

This post is part of our guide to the EU AI Act for voice agents, which covers what a phone agent must do now. Below are the rule in plain words, the Commission's advice and sample lines, then the setup in Dograh, the open-source AI voice agent platform we build.

What Article 50 says, in plain words

The rule is one sentence long. Article 50 of the AI Act says providers must design AI systems that interact directly with people so that the people concerned are "informed that they are interacting with an AI system", unless that is obvious to a reasonably well-informed person. This interaction notice must be clear and distinguishable, and it must come at the latest at the time of the first interaction.

Two more conditions sit in the same article. The notice has to meet the accessibility rules that apply, so it must work for people with disabilities, and it adds to any other transparency duty in EU or national law instead of replacing it. A financial or debt collection call that already needs a fixed disclosure needs both.

The duty sits with the provider, the company that builds the AI system or has it built and puts it into service under its own name. A business that builds its own phone agent counts, even on an open-source platform. It has applied since 2 August 2026, and the AI Omnibus did not move it.

How the Commission wants it said on a call

The Commission's Article 50 guidelines, adopted on 20 July 2026, give specific advice for voice. In telephony, they point to an explicit spoken statement at the beginning of the call, with "This is an AI-powered assistant" as the example. They list voice assistants used in customer support, complaints, e-commerce, finance and healthcare among the systems in scope.

They also ask for reminders in longer calls, especially after an interruption or when the AI's role changes, for example when the agent moves from answering questions to booking an appointment. Tones or earcons can help people with a visual impairment recognise the AI, but the guidelines say they are not enough by themselves. A beep before the greeting does not replace the words.

The notice also has to say something a caller can understand. "You're speaking with an AI assistant" works. A line that only names a product, or says "automated system" in passing halfway through the greeting, is weaker evidence that the caller was told.

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When you can skip the notice, and when you cannot

The obvious exception exists, but it is narrow. The Commission's questions and answers say it should be read restrictively, because it takes transparency away from people, and that you judge it by a reasonably well-informed, circumspect and observant person. Fines for getting it wrong can reach 15 million euros or 3% of total worldwide turnover.

The guidelines name the tone of the voice, robotic or human-sounding, as one factor. Modern synthetic voices sound human, so that factor now cuts against skipping the notice. The guidelines also say the exception cannot be relied on where the public may call, including older people or people with lower AI literacy, and add that consumer law applies whether or not the AI is obvious.

So for any line the public can reach, plan on giving the notice on every call. Our reading is that the exception mostly helps internal tools whose users already know they are talking to a system, and that reading, like your own position as provider or deployer, is worth confirming with counsel.

Sample opening lines you can adapt

The lines below are examples, written from the Commission's own example and the timing rule. Each says it is an AI before it asks for anything. Adapt the business name and topic, and keep the AI sentence near the start with its variable fallbacks.

• Inbound, example: "Hello, this is the automated assistant for [Business]. I'm an AI. How can I help?"
• Outbound, example: "Hi {{customer_name | there}}, this is an AI assistant calling for [Business] about your [topic]."
• Bilingual, example: "Bonjour, hello. Vous parlez avec l'assistant IA de [Business]. You're speaking with [Business]'s AI assistant."
• With a recording notice, example: "Hello, you're speaking with [Business]'s AI assistant. This call is recorded. How can I help?"

The recording sentence is there for a different law. Article 50 says nothing about recording, so the notice for it follows national law and the GDPR, as our post on call-recording consent laws explains. For German wording, our post on German AI voice agents for banking has a full greeting.

Make the notice play in full in Dograh

In Dograh, which you can self-host or run on Dograh Cloud, the opening line is the Greeting Text on the Start Call node. It plays word for word through text-to-speech at the start of the call, so the AI sentence is never left to the model. If you would rather use a real voice, set Greeting Type to a pre-recorded clip.

Allow Greeting Interruption is on by default, and a caller who says two words while the greeting plays can cut it short. Switch it off on the Start Call node. Dograh then holds the caller's speech until the greeting finishes, so every caller hears the whole notice, and the agent still hears what they said.

Variables need care. A missing value is spoken as empty text, so Hi {{customer_name}} with no name is spoken as a bare "Hi". Write a fallback value, as in {{customer_name | there}}. For outbound campaigns, add a greeting override column to the contact list so each person hears the notice in their own language.

Reminders later in the call are written by the model when they come from a prompt, so they vary. Run QA on a sample of calls to check the notice was heard, and keep the recordings. Our EU AI Act timeline shows which other dates are coming for voice systems.