Tidio, Intercom, Gorgias and EU AI Act Article 50: What Your Chatbot Still Needs

Last updated: 25 June 2026

Guidance only, not legal advice. Based on EU AI Act Regulation (EU) 2024/1689 and the Commission's draft Article 50 guidelines (May 2026).

If you're running a chatbot on your website — whether it's Tidio, Intercom, Gorgias, Re:amaze, Drift, HubSpot Chat, Zendesk, or the built-in AI chat on Wix or Squarespace — EU AI Act Article 50 applies to you from 2 August 2026.

Most of these platforms will tell you they're "working on compliance" or that they already show an AI label. That's partially true — and completely insufficient to protect you. Here's the distinction that matters.

The core issue: Your chatbot platform is the provider. You are the deployer. Article 50 places separate, non-delegable obligations on each. What your platform does covers their obligation. Your obligation is yours alone.

What the provider/deployer split means in practice

The EU AI Act draws a hard line between the company that builds an AI system (the provider) and the business that deploys it on their own site to interact with their own customers (the deployer). Tidio, Intercom, Gorgias — these are providers. You are the deployer.

As the deployer, Article 50(1) requires you to ensure that a clear, distinguishable AI disclosure appears to your visitors at the very first interaction. The obligation sits with you regardless of what your platform does on their end. Your platform's compliance page protects them. It does not protect you.

And critically: even if your platform shows a generic "Powered by AI" label, you have no server-side record of when and how many times that disclosure fired for your visitors. That timestamped evidence log is your responsibility — and no chatbot platform provides it for you.

Platform by platform: what they cover and what they don't

Tidio

Tidio is one of the most popular chatbot platforms for Shopify and WordPress stores. As a provider, Tidio is responsible for building a system that can be configured to show an AI disclosure. Whether they do this — and what form it takes — is their obligation. Your obligation as the deployer: ensure a clear AI disclosure appears at first interaction on your site, in the language of your EU visitors, and that you have a record of when it fired. Tidio's branding or "Powered by Tidio AI" label does not constitute a compliant Article 50 disclosure — it identifies the platform, not the AI nature of the interaction.

Intercom

Intercom's Fin AI agent and other AI features are used by thousands of EU-serving businesses. Intercom has published some guidance on Article 50. As the deployer, what matters is whether your specific Intercom deployment shows a compliant first-interaction AI disclosure — not whether Intercom has a compliance blog post. Intercom's bot name or avatar does not automatically satisfy the "clear and distinguishable" standard. Your obligation: configure Intercom's opening message to include explicit AI disclosure, verify it appears before or at the first user message, and maintain a separate evidence log of disclosure events on your site.

Gorgias

Gorgias is heavily used by Shopify merchants for AI-powered customer support. As with other platforms, Gorgias as provider must enable the technical disclosure mechanism. As the deployer running Gorgias on your store, you must ensure the disclosure is actually happening — clear, at first interaction, in the right language, and documented. Gorgias's own automation labels or "powered by" branding do not constitute your Article 50 compliance.

Re:amaze

Re:amaze is popular with Shopify and WooCommerce merchants. The same deployer obligation applies: you must ensure compliant AI disclosure at first interaction on your specific store, independently of what Re:amaze does on their end. Configure Re:amaze's chatbot opening message to explicitly identify the AI nature of the interaction.

HubSpot Chat and Drift

HubSpot's chatbot and Drift (now part of Salesloft) are common on SaaS and B2B sites. Both platforms have AI features. As the deployer — the business using these tools to interact with site visitors — Article 50 requires you to ensure compliant AI disclosure at first interaction. Neither platform's live chat label or branding constitutes a disclosure of AI interaction for Article 50 purposes.

Zendesk

Zendesk's AI agents and Answer Bot are widely used for customer support. Zendesk as provider has obligations on their side. You as the deployer remain responsible for ensuring your Zendesk implementation discloses AI at first interaction clearly and distinctly — and that you have evidence it fired for your visitors. Zendesk's own "powered by" labels do not substitute for this.

Wix, Squarespace, and other website builders with built-in AI chat

Wix and Squarespace have added AI chat and AI assistant features to their platforms. If you're using these built-in tools to interact with visitors, you are the deployer. The fact that Wix or Squarespace is both the website platform and the chatbot provider doesn't change your Article 50 obligation — you still need a clear first-interaction AI disclosure visible to your visitors, in the right language, and you need a documented record. Neither Wix nor Squarespace currently provides a deployer-level evidence log for Article 50 compliance. That gap is entirely yours to fill.

What you actually need — regardless of which platform you use

The platform doesn't matter. The obligation is the same. Here's what every deployer needs before 2 August 2026:

  1. A clear AI disclosure at first interaction. The chatbot's opening message — or a persistent visible label before the user types — must identify that the user is talking to AI. "This chat is powered by an AI assistant" at the start of the conversation is sufficient. It must be in clear language, not buried in an icon or a faint label.
  2. In the right language. The EU Commission's draft guidelines indicate disclosure should be in a language your users understand. If your site serves Dutch, German, or French visitors, the disclosure needs to be in that language — not just English.
  3. A timestamped evidence log. You need a server-side record showing the disclosure fired, when, and how many times. Your platform's settings screen is not this record. A screenshot is not this record. You need a log you can export and hand to a regulator.
  4. Accessibility compliance. The disclosure must be clear and distinguishable — adequate font size, contrast, visible on mobile. A grey "AI" icon in 9px text does not meet the standard.
The evidence gap is the real problem. Every platform listed above can help you show a disclosure. None of them provide you with a server-side timestamped log of every disclosure event on your specific site — the kind of record that helps demonstrate to an authority that your disclosure was shown. That is exactly what Disclo Pro's evidence log provides, automatically, from the moment you paste one line of code.

The competitor complaint risk you haven't thought about

Enforcement under Article 50 is most commonly triggered not by random audits, but by complaints — from users, consumer organisations, journalists, and competing businesses. A competitor who knows you're not compliant can file a complaint with your national market surveillance authority. The authority will ask you to prove your disclosure was in place and firing from 2 August 2026.

"My chatbot platform has a compliance page" is not proof. A server-side evidence log with timestamped disclosure events is.

The deadline and the fine

Article 50 becomes enforceable on 2 August 2026. This deadline was not affected by the EU Omnibus agreement of May 2026. Fines for non-compliance are up to €15 million or 3% of global annual turnover, whichever is higher, under Article 99 of the AI Act. Documented good-faith compliance — including a timestamped evidence log — is an explicit mitigating factor.

If you're using any of the platforms above, the free Article 50 Scope Check at disclo.eu will confirm exactly what Article 50 requires from your specific setup in under two minutes.