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Does the EU AI Act apply to a customer service chatbot?

The system being classified

You provide a chatbot that answers customer questions on a website. It makes no decision about anyone and touches no Annex III category.

Verdict

Limited risk — transparency duties

No high-risk category applies, but Article 50 transparency obligations do. These are cheap to fix and expensive to ignore.

3 applicable obligations
Maximum fine tier: €15,000,000 or 3% of global annual turnover (for breached obligations)
Key date: Article 50 transparency duties apply since 2 August 2026; GPAI duties since 2 August 2025

This is the classification of the configuration described above, not of your system. One different answer can move it — which is exactly what the comparison further down shows, and what the free assessment settles in about ten minutes.

What produced this verdict

These are the entire inputs. The engine is deterministic, so these answers always produce the verdict above.

Article 50 transparency triggers

  • · People interact directly with the AI (chatbot, voice agent)

Scope and role

  • · Provider — you build it or place it on the market under your name
  • · Placed on the EU market, or output used in the EU

What applies, and from when (3)

Every entry cites the article it comes from and the date it binds. That second column is the part most summaries of the Omnibus get wrong.

ArticleObligationBinding from
Art. 4
AI literacy
Ensure staff dealing with AI systems have a sufficient level of AI literacy (training records recommended).
2 February 2025
Best practice
AI system inventory
Maintain a central register of all AI systems in use, their purpose, risk tier and owner.
Good practice
Art. 50(1)
Disclose AI interaction
People must be informed they are interacting with an AI system, unless obvious from context.
2 August 2026

What would change this verdict

Each row below is the same scenario with one answer changed, re-run through the same engine. These are not predictions about your system; they are what our classifier returns when that single fact differs. Where one change to the scenario necessarily moves a second answer with it, the row says which, and why.

The bot also decides who gets a refund or a service

Becomes high-risk system

Access to essential services is an Annex III category, and a conversational interface does not keep a decision system out of it.

  • Obligations: 315 (+12)
  • Key date changes to 2 December 2027 — Annex III high-risk obligations apply (postponed from 2 August 2026 by the 2026 Omnibus); Article 50 transparency duties apply already

You also trained the underlying general-purpose model

Same risk tier

GPAI model duties under Articles 53 and 55 attach to the model provider, independently of what any downstream system does.

  • Obligations: 36 (+3)

Your system is not this system

The assessment asks the same questions this page answered for a generic configuration, and produces the verdict, the gap list and the 30-day plan for yours. Ten minutes, free, no sign-up, and it runs entirely in your browser — your answers never reach us.

Classify your own system →

Other configurations

Produced by rule set 1.6.1, legal state 2026-08-05. The engine is deterministic and contains no language model in the verdict path, and every rule is published at /methodology for you to audit.

AnnexWise is preparation software, not legal advice. This page classifies a described configuration; it is not an opinion on any particular organisation or system.