Has the EU AI Act been postponed?

Partly. Under the Digital Omnibus, the deadlines for high-risk AI systems were postponed to December 2027 and August 2028 respectively. The transparency obligations under Art. 50 AI Act are not affected by this postponement and have applied unchanged since August 2, 2026.

Does Article 50 apply to chatbots?

Yes. Art. 50 AI Act requires providers and deployers of AI systems that interact directly with natural persons, such as chat assistants, to disclose that it is an AI system, unless this is already obvious.

Does a chatbot have to disclose that it is AI?

Yes, unless it is already obvious to the user that they are interacting with an AI system. LoyJoy implements this through an AI notice in the greeting module, a customizable AI label on every AI-generated message, and a permanent notice line below the input field.

Does an AI phone assistant have to disclose that it is AI?

Yes. The transparency obligation under Art. 50 AI Act also applies on the phone. LoyJoy provides a configurable default greeting that clearly informs the caller at the start of the call that they are speaking with an AI system.

Who is the provider and who is the deployer?

LoyJoy is the provider of the AI-powered SaaS platform and of the AI system built on top of it. The customer who uses the platform in their chat or telephony is generally the deployer of the specific AI system within the meaning of the AI Act and is responsible for how it is configured and used in their specific use case.

Brief Statement on the EU AI Act for LoyJoy

Change history (7 entries)

10/08/2026 The speech-to-speech model of the Phone Agent now runs in the EU Data Zone of Azure OpenAI instead of via global Azure services. Data Protection section updated accordingly.
05/08/2026 Added Digital Omnibus update: high-risk deadlines postponed to December 2027 and August 2028, Art. 50 transparency obligations unaffected and unchanged in force since August 2, 2026. Added December 2, 2026 deadline for existing systems regarding labelling of synthetic audio content (technical implementation under review). Added deadline timeline and FAQ section with FAQPage schema.
30/07/2026 Split the Transparency Obligations section into 'Chat' and 'Phone Agent'. Added chat transparency details: AI notice in the greeting module, customizable AI label on AI-generated messages, permanent notice line below the input field. Made the labelling of AI chat messages a binding statement.
03/07/2026 Clarification added that LoyJoy operates the GPAI model Gemma 4 on its own hardware in the Münster data center. Role under Art. 3 no. 3 and Art. 25(1)(c) AI Act clarified.
06/05/2026 Standard Phone Agent greeting documented. Platform note on responsibility for modified greetings added.
05/05/2026 LoyJoy role extended to include Phone Agent and speech-to-speech. Transparency obligations for Phone Agent conversations added. Obligations table updated.
20/05/2025 Initial publication of the AI Act statement.

Deadlines at a glance

August 2, 2026

The transparency obligations under Art. 50 AI Act take effect, for direct contact with AI systems via chat and phone.
December 2, 2026

Implementation deadline for labelling synthetic audio content for generative systems already on the market before August 2, 2026.
December 2027

New deadline under the Digital Omnibus for part of the high-risk obligations.
August 2028

New deadline under the Digital Omnibus for further high-risk obligations.

Brief Statement on the EU AI Act for the LoyJoy Platform

This brief statement explains how LoyJoy, as a platform provider, implements the obligations of the EU AI Act, in particular the transparency obligations under Art. 50 for direct contact with AI systems via chat and phone.

Digital Omnibus

What was postponed, and what wasn't

Under the "Digital Omnibus", the deadlines for high-risk AI systems were postponed, to December 2027 and August 2028 respectively.

Not postponed are the transparency obligations under Art. 50 AI Act for direct contact with AI systems. These have applied unchanged since August 2, 2026.

Role of LoyJoy

LoyJoy provides enterprise customers with a SaaS platform for creating and running AI-powered customer interactions via chat and telephone. LoyJoy does not develop its own foundation models.

As the default model for chat interactions, LoyJoy operates the GPAI model Gemma 4 from Google on LoyJoy-owned hardware in the Münster data center. Google remains the provider of the GPAI model within the meaning of Art. 3 no. 3 and Art. 51 et seq. AI Act; the GPAI-model provider obligations continue to rest with Google. LoyJoy does not carry out any substantial modification of the model within the meaning of Art. 25(1)(c) AI Act (no fine-tuning, no further training), and the on-prem hosting alone does not turn LoyJoy into a provider of the GPAI model. LoyJoy continues to act as the provider of the AI system built on top of the model.

In addition, depending on the configuration, AI models and speech-to-speech services from sub-processors such as Microsoft Azure, Mistral, Scaleway, Nebius or Anthropic are used.

In relation to end users, the customer is generally the operator of the specific AI system and the controller responsible for the specific use case. LoyJoy supports customers as a platform provider and data processor through technical and organisational features for transparent and GDPR-compliant use.

Transparency Obligations

The transparency obligations under Art. 50 AI Act have applied since August 2, 2026, and are not affected by the postponement of the high-risk deadlines proposed under the Digital Omnibus.

Chat

For chat interactions, LoyJoy provides an AI notice in the greeting module that informs the user at the start of the conversation that they are interacting with an AI system. Every AI-generated message is additionally labelled with a customizable AI label. LoyJoy also displays a permanent notice line below the input field, visible throughout the entire conversation.

Ready-to-use text templates for the greeting module and notice line are available under AI Notice Text Templates.

Phone Agent

For Phone Agent conversations, LoyJoy provides a configurable default greeting that informs the caller at the beginning that they are interacting with an AI system. The default greeting reads:

“Hello, I am the AI telephone assistant of [Company name]. The call will be temporarily stored to process your request, and of course treated confidentially. How can I help you?”

Customers may adapt this greeting to their use case. The platform includes the following notice: “The greeting should clearly state that the caller is speaking with an AI system. If you remove this notice, you are responsible for the legal assessment of your modified greeting.”

If call recordings are used, the controller must additionally assess whether and in what form a separate notice or consent from callers is required for the recording.

Ready-to-use text templates for the phone greeting are also available under AI Notice Text Templates.

Operator Obligations and Implementation

Obligation	Implementation at LoyJoy
Transparency for direct AI interaction, Art. 50 AI Act	AI-generated chat messages are labelled through an AI notice in the greeting module, a customizable AI label, and a permanent notice line. For Phone Agent interactions, LoyJoy provides a default greeting with a clear AI notice.
Labelling of synthetic audio content, Art. 50 AI Act	In speech-to-speech dialogues, the caller is informed at the beginning of the interaction that they are speaking with an AI system or AI telephone assistant. For generative systems already on the market before August 2, 2026, an implementation deadline until December 2, 2026 applies.
Logging	Conversation data, including transcripts and call recordings, is stored according to tenant configuration, 30 days by default.
Human oversight	Customers can configure and review process logic, knowledge sources and responses. A handover to human agents can be included per process.
Cybersecurity	Encrypted transmission, role-based access control, logging, sub-processors with documented security measures.

Data Protection

Processing as a data processor pursuant to Art. 28 GDPR.
By default, Gemma 4 is operated as the chat LLM on LoyJoy-owned hardware in the Münster data center (Germany). For this default path, no personal data is transferred to an external AI model provider.
Further LLM processing takes place in EU regions by default. LoyJoy offers a selection of AI models from various providers operated in the EU. For customers not subject to the EU AI Act, LoyJoy additionally makes AI models with server locations in the USA available. These are clearly labelled in the platform and are not configured as the default for EU customers.
Since August 2026, the speech-to-speech model of the Phone Agent has been processed in the EU Data Zone of Azure OpenAI.
Encrypted storage and transmission of personal data.