Official-source-backed technical resource

Identify an AI avatar during interactive sessions

Make the artificial nature of an interactive avatar clear in the session entry and ongoing presentation. Includes a free implementation worksheet.

Short answer

Make the artificial nature of an interactive avatar clear in the session entry and ongoing presentation. Review realistic appearance and voice without assuming a visual style makes the identity obvious.

Download the blank working record (.md)

When to use this guide

A realistic service avatar uses a human name and starts a two-way conversation while the AI label appears only in an account menu.

This is a fictional implementation scenario. The procedure below is Article 50 Hub's suggested working method, not a prescribed legal form, a customer result or a claim that every step is an additional statutory requirement.

Review procedure

  1. Document the avatar's visual, voice and naming cues in the intended context.

  2. Place identity wording in the entry state before the interactive exchange.

  3. Test full-screen, audio-only and reduced-layout modes.

  4. Save representative evidence and route any proposed obviousness exception for qualified review.

What the example review finds

  • The avatar's presentation suggests a live employee.

  • The label disappears in full-screen mode.

Keep these example observations separate from your own results. An unknown or untested state should stay open until the relevant evidence has been inspected.

Fields for your working record

  • Avatar mode

  • Identity wording

  • Entry timing

  • Full-screen behavior

  • Review decision

Use the downloadable blank worksheet linked on this page to connect the observed behavior with the deployed system. Add a reviewer, date, evidence reference, unresolved questions and a next action. The worksheet is editable locally and does not upload your records to Article 50 Hub.

Completion and handoff

Close the task only for the scope actually reviewed. Preserve the result that another authorized reviewer can reproduce, identify the owner of remaining work, and record a retest when the implementation changes. A completed worksheet is not a substitute for the underlying evidence.

Decision boundary

An identity notice does not resolve separate rights, biometric, deepfake or sector-specific issues.

The official references below provide legal or technical context. Resolve applicability and exception questions with the responsible qualified reviewer; use the product's tools to organize implementation work within that assessment.

Official sources

  1. EU AI Act — legal text and contextEUR-Lex
  2. Commission FAQ — transparency obligations and scopeEuropean Commission
  3. Article 50 Service Desk — read with its amendment notice and current Commission guidanceEuropean Commission
  4. W3C — evaluating accessibility and the limits of automated checksW3C WAI

Last reviewed: 2026-09-23. This is technical implementation information, not legal advice.

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