Must German Shops Disclose AI Chatbots?

In short: yes. If your German online shop uses an AI chatbot or voice assistant that interacts with customers, Article 50 of the EU AI Act (Regulation (EU) 2024/1689) requires you to tell people they are dealing with an AI system.

Where the duty comes from

The AI Act is a Regulation, so it applies directly in Germany without a separate national statute. Article 50 places transparency duties on deployers — and a shop that uses a third-party chatbot is normally a deployer. The rule is simple: a person interacting with the AI must be informed of that fact, unless it is already obvious to a reasonably observant person.

What good disclosure looks like

• Show the notice at the first interaction, not buried in a policy page.
• Write it in plain German for a German-facing shop.
• Keep it clear — a short line such as “You are chatting with an AI assistant” suffices.

The “already obvious” exception is narrow. If your bot is styled to look like a human agent with a real name and photo, you cannot rely on obviousness; disclose expressly.

Why German specifically

Article 50 disclosures must be clear and distinguishable. German consumer-information expectations reinforce this: information directed at German consumers should be understandable to them. A disclosure only in English is a weak defence for a shop trading into Germany.

National market-surveillance authorities for the AI Act were still being designated across Member States in 2025-2026, so the exact German enforcement body is best checked at the time. That does not change the underlying duty, which applies now. See our AI Act overview.

This article is educational, not legal advice.