Your hotel's AI chatbot and the EU AI Act: what you must disclose since August 2026

Updated: 9 November 2026

More and more hotels answer on their website, Instagram or WhatsApp with an AI assistant. Since 2 August 2026 the transparency rules of the EU AI Act (Regulation (EU) 2024/1689, Article 50) apply. This is what the text and the Commission's guidelines say (sources at the end). It is not legal advice: for a specific question, ask your adviser.

The basic rule

An AI system that converses with people must be designed so they know they are talking to an AI, unless it is obvious. The notice must be given at the latest at the first interaction. The Commission put it this way: chatbots "will have to tell users they are dealing with AI, not a human".

Was it postponed by the Digital Omnibus?

Not this part. Regulation (EU) 2026/1744, which amended the AI Act in July 2026, delayed the high-risk obligations, but Article 50 applies from 2 August 2026. It only gave providers of generative AI already on the market until 2 December 2026 to technically mark the content they generate.

Who is responsible: the hotel or the chatbot company?

Disclosing that it is an AI is an obligation of the "provider": whoever develops the chatbot or places it on the market under its own name.
If you use a third-party chatbot, under the Commission's guidelines you are a "deployer" and your own obligations are different (the content ones, below). Even so, check that the chatbot introduces itself as AI: that is what your guest will see.
If you built it yourself and offer it under the hotel's name, you could be the provider. The guidelines do not discuss hotel cases: ask your adviser.
The "it is obvious" exception is interpreted restrictively: the Commission gives chatbots embedded in online platforms or helpdesks as an example of a case that is not obvious.

AI-generated photos, videos and texts

Whoever publishes AI-generated or manipulated images, audio or video that look real (deep fakes) must say so. So must texts published to inform the public on matters of public interest, unless a person reviews them and takes editorial responsibility. There is no official guidance on a hotel's marketing texts. Mind the platforms too: Google, for example, does not accept AI-generated photos on a Business Profile, and an invented room photo misleads the guest.

Fines and who enforces

Breaching Article 50 can cost up to EUR 15 million or 3% of worldwide turnover; for SMEs the lower amount applies.
Spain: AESIA (designation pending; the government approved the AI bill on 26 May 2026).
Italy: the National Cybersecurity Agency (ACN).
Portugal: ANACOM (designation pending).
Greece: the Hellenic Data Protection Authority.

5-minute check

Open your website or WhatsApp as a guest would: does the first message clearly say it is an automated or AI assistant?
Ask it "are you a person?" and see what it answers.
Ask the chatbot company to confirm in writing how it complies with Article 50.
Check that no photo on your website or listings is an AI-invented image presented as real.

How iQuota helps

iQuota does not put a chatbot on your website: it publishes your real data and prices so that the AI assistants travellers already use (ChatGPT, Gemini, Claude…) read them correctly, and the traveller knows they are talking to their assistant. Nobody can guarantee that an AI will recommend you.

Want an official booking page AI can read and a connector with your real prices, commission-free? The first 30 hotels join free until 30 June 2027.

See the Founding Hotels programme

Frequently asked questions

Do I need a notice if I answer WhatsApp myself?

No: the rule is for AI systems. If you or your staff answer, there is nothing to disclose.

What if I only use AI to draft replies that I review and send?

Then the guest is talking to a person who signs the message. The Article 50(1) notice is for systems that converse directly with the person.

Since when does it apply?

Since 2 August 2026. The Digital Omnibus did not postpone it.

Sources

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