By industry · Written by Yobel Tzegai · Last checked 9 October 2026

Is AI in customer service covered by the EU AI Act?

Customer service AI under the EU AI Act: chatbots must say they are AI (Article 50(1)), emotion recognition is high-risk, Article 4 applies to all.

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The answer, in detail

Where a customer service system usually sits
SystemUsual outcomeProvisionApplies from
A chatbot or voice agent answering customersTransparency duties for its providerArticle 50(1); Article 50(2) where it generates content2 August 2026, under Article 113, second paragraph; Article 50(2) by 2 December 2026 for a system placed on the market before 2 August 2026 (Article 111(4))
Drafting replies that an agent sendsNo duty of its own beyond Article 4Article 4, as replaced by Regulation (EU) 2026/17442 February 2025, under Article 113, third paragraph, point (a), as replaced
Emotion recognition on customers’ voices or facesHigh-risk, and its deployer informs the people exposedPoint 1(c) of Annex III; Article 50(3)2 December 2027 for the high-risk duties (Article 113, third paragraph, point (c), as replaced); 2 August 2026 for Article 50(3) (Article 113, second paragraph)
Inferring your own agents’ emotions at workProhibited, except for medical or safety reasonsArticle 5(1), first subparagraph, point (f)2 February 2025, under Article 113, third paragraph, point (a), as replaced

What does a customer service chatbot owe?

Is sentiment analysis emotion recognition?

What applies to every use?

Your customer asks. You answer with proof.

  1. 1List every AI system

    Add the AI you use. Each system gets a role, a risk class and the article it rests on.

    Live
  2. 2Attach the proof

    Link each duty to a file and the page it stands on: a policy, a log setting, a training record.

    Live
  3. 3Answer their questionnaire

    Answering a customer's questionnaire inside the app, from the proof you already linked.

    Coming soon

What Complipath does

  • Risk classification Answers go through rules in code, never a language model, so the same answers always give the same result. Rules decide. AI only drafts. A person confirms.
  • AI inventory Every AI system you build or use, with its owner and risk class
  • AI literacy (Article 4) Records who was trained on what and when, against the Article 4 duty to support AI literacy, which applies whatever your risk level
  • Obligations per system Confirming a classification creates the obligations that follow from it, each with an owner, a status and a place for evidence

Rules decide. AI only drafts. A person confirms.

What it does not do yet

  • Customer questionnaires (audit room) Coming soon Coming soon: answering a customer's AI questionnaire from your own register.
  • Domain-specific guidance Not supported Guidance written for one sector.

What is live today

Checked against the app on 8 October 2026
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Questions

Do we have to tell customers they are talking to a bot?

The system must be designed so they are informed, unless it is obvious to a reasonably well-informed, observant and circumspect person in the circumstances (Article 50(1)). The duty is the provider’s; if you bought the bot, ask its provider how it meets it. Article 50 applies from 2 August 2026, and Article 50(2) from 2 December 2026 for a generator already on the market (Article 111(4)).

Is routing tickets with AI high-risk?

Not as such. Annex III does not list ticket routing or reply drafting. Point 5(d) lists AI systems that evaluate and classify emergency calls, dispatch emergency first response services or establish priority in dispatching them, and emergency healthcare patient triage systems. Point 5 also lists eligibility for public assistance benefits evaluated by or on behalf of public authorities (point (a)); creditworthiness, except fraud detection (point (b)); and life and health insurance pricing (point (c)).

Read next
See what your customers will ask about your AI.No account needed. Every answer cites the article it rests on.