Official-source-backed technical resource

Document an AI interaction obviousness assessment

Record the real audience, presentation and context before considering whether AI identity is obvious. Includes a free implementation worksheet.

Short answer

Record the real audience, presentation and context before considering whether AI identity is obvious. Keep the assessment reviewable and avoid using an internal product nickname as evidence.

Download the blank working record (.md)

When to use this guide

A team assumes that an assistant named Nova is obviously AI, although its interface resembles a human account manager.

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. Capture the actual entry screen, name, avatar, voice and service context.

  2. Describe the expected audience and how they would understand those cues.

  3. Record the qualified reviewer's reasoning and any uncertainty about the proposed exception.

  4. Reopen the assessment when the presentation or audience changes.

What the example review finds

  • The name alone does not explain the participant's identity.

  • A redesigned human portrait changes the original assessment context.

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

  • Audience

  • Presentation cues

  • Context

  • Reviewer reasoning

  • Reassessment trigger

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

This worksheet does not grant an exception or establish that a notice may legally be omitted.

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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