European Accessibility Act and AI use cases

The conversational assistant falls under the Article 50 transparency duty. Biometric verification whose sole purpose is to confirm that a person is who they claim to be is excluded from the Annex III biometric category. The system becomes high risk when the same journey assesses creditworthiness or a credit score of a natural person, for example for a credit card or overdraft (Annex III point 5(b)).

Writing product content and extracting catalog attributes is not an Annex III use and makes no decisions about people. When a retailer uses a third party generator, the use is minimal risk for the retailer: the Article 50(2) duty to mark generated text in a machine readable way falls on the provider of that system. When a retailer builds and operates its own generating system and puts it into service under its own name, it is the provider and must mark the output, unless the exception for systems that only assist standard editing or do not substantially alter the input applies. Article 50(4) covers text published to inform the public on matters of public interest, not product listings. Consumer protection law applies to what the listing says in every case.

Transcription and captioning are not listed in Annex III and are not a prohibited practice under Article 5, so the tier depends on how captions are published. Article 50(4) requires deployers to disclose AI generated or manipulated text published to inform the public on matters of public interest, such as news captions, unless it has undergone human review or editorial control and someone holds editorial responsibility, so the editor step keeps most deployments outside this duty. The provider duty to mark output in Article 50(2) does not apply where the system does not substantially alter the input or its semantics, which fits same language transcription better than translated subtitles. Unreviewed news captions or subtitles should therefore be disclosed as automatic.

Article 50(1): people must be informed that they are interacting with an AI system, unless that is obvious from the context. Servicing existing accounts and cards is not an Annex III use. It would become high risk under Annex III point 5(b) if the agent itself evaluated the creditworthiness of a natural person, for example to decide a credit limit increase.

A customer facing assistant must tell people they are interacting with an AI system unless that is obvious (Article 50(1)). It does not evaluate creditworthiness (Annex III point 5(b)) or eligibility for public assistance benefits (point 5(a)), so it is not high risk; biometric verification whose sole purpose is to confirm identity is excluded from Annex III point 1(a).

Article 50(1): people must be told they are interacting with an AI system unless that is obvious. Finding locations and booking appointments does not fall under any Annex III category. If a healthcare version starts to triage patients by urgency, or a public body uses it to decide eligibility for a public service, reassess it against Annex III point 5.

An AI system that interacts directly with people must be designed so that they know they are dealing with AI, unless that is obvious from the context (Article 50(1)). It is not high risk under Annex III as long as it does not evaluate eligibility for essential public assistance benefits and services (point 5(a)), creditworthiness (point 5(b)), risk and pricing for life and health insurance (point 5(c)) or emergency calls (point 5(d)). This holds only if emotion or vulnerability signals are inferred from what the customer says (text or transcript content), not from voice or other biometric features; an agent that infers emotion from a caller's voice is an emotion recognition system (Article 3(39)), which is high risk under Annex III point 1(c) and triggers the deployer disclosure duty in Article 50(3).

A customer facing assistant must tell people they are interacting with AI (Article 50). It is not a high risk use under Annex III: it applies the airline's reaccommodation rules and does not decide on access to an essential public service or on creditworthiness.

A customer facing service agent must disclose that the customer is interacting with AI (Article 50). It is not high risk: it does not decide on access to essential services, credit or employment.

A digital human or kiosk that talks to customers must be designed so that they are told they are interacting with an AI system (Article 50(1)). An associate copilot over product content is not listed in Annex III and is minimal risk. Inferring the emotions of employees at work is prohibited (Article 5(1)(f)); emotion recognition of customers by camera is high risk under Annex III point 1(c), biometric categorisation by sensitive or protected attributes is high risk under Annex III point 1(b), and categorisation that infers race, political opinions, religion or sexual orientation is prohibited under Article 5(1)(g). Both need separate legal review.

A shopping assistant interacts directly with people, so under Article 50(1) shoppers must be informed that they are dealing with an AI system unless that is obvious. It is not listed in Annex III, so it is not high risk. Manipulative or deceptive techniques that materially distort a shopper's behaviour and cause significant harm are prohibited under Article 5(1)(a), which matters for how persuasion and urgency are designed.

A customer facing assistant must tell people they are interacting with AI unless that is obvious from the context (Article 50(1), applicable from 2 August 2026). Recommending and booking travel is not listed in Annex III, so it is not high risk; consumer protection law on price transparency and fair commercial practices still applies to what it says.