Classification memo
Customer-support chatbot
This system interacts directly with members of the public, so under Article 50(1) you must clearly disclose that they are dealing with an AI system at first contact. It is not high-risk under Annex III and triggers no Article 5 prohibition.
Article 5 — prohibited
Clear
No banned practice in scope.
Annex III — high-risk
Not high-risk
No Annex III domain matched.
Article 50 — transparency
50(1) applies
Disclosure at first contact.
Confidence
High
Clear-cut deployment.
What would change this
If the bot began making or materially influencing decisions about people — eligibility, pricing, or access to a service — it could move into Annex III high-risk and require a Fundamental Rights Impact Assessment (Article 27).