Since 2 August 2026 the transparency obligations in Article 50 of the EU AI Act apply. The Digital Omnibus on AI, published in July 2026, moved several deadlines for high-risk systems, but it left this date in place. Hotel owners keep asking the same question: do I now have to tell guests that a reply was written with AI?
The short answer for most hotels: not for an email or a review reply that a person has read and approved. The longer answer depends on what you use AI for.
This is general information, not legal advice.
Who has which duty
Article 50 divides duties between providers (the companies that build and sell AI systems) and deployers (businesses that use them, like a hotel).
Providers must:
- design systems that interact directly with people, such as chatbots, so that people are told they are dealing with an AI, unless it is obvious;
- mark AI-generated content in a machine-readable way, so it can be detected. For systems already on the market before 2 August 2026, this marking duty applies from 2 December 2026.
Deployers must inform people when they are exposed to:
- deepfakes: AI-generated or manipulated images, audio or video of real people, places or events;
- AI-generated text published to inform the public on matters of public interest, unless it has gone through human review or editorial control and someone holds editorial responsibility;
- emotion recognition or biometric categorisation systems.
What this means in a hotel
Guest emails and messages. A reply to one guest about their booking is not a publication on a matter of public interest. When a person at the hotel reads it, corrects it if needed and sends it, there is no labelling duty under Article 50.
Review replies. A reply to a review is public, but it is about one stay, not a matter of public interest in the sense of the Act. With a person approving each reply, there is no Article 50 duty to label it.
A chatbot on your website. If guests chat with an AI assistant directly, they should know it is an AI. The provider must build that in, and as the hotel you should not hide it. A visible line such as “I’m the hotel’s AI assistant; a person replies to anything I can’t answer” is a good habit and good service.
Photos and videos. AI-generated images of your hotel that look real, used in marketing, deserve particular care. Images that show a terrace, a view or a room that does not exist raise consumer-law problems long before the AI Act. Use AI for drafts and ideas, not to show guests things they will not find.
Simple habits that keep you clear
- A person approves every message and review reply before it is sent. Keep it that way.
- Say so when guests talk to a bot.
- Do not publish realistic AI images or video of your property as if they were photographs.
- Keep using business AI accounts with a data processing agreement; the GDPR still applies to everything above.
The European Commission published guidelines on Article 50 and a Code of Practice on transparency of AI-generated content in July 2026. Both are worth a look if you build anything more ambitious than drafts.
Sources
- AI Act Service Desk: Article 50
- European Commission: Transparency obligations under Article 50, questions and answers
- European Commission: Guidelines on transparency obligations (20 July 2026)
- AI Act Service Desk: When does enforcement start?
Read on 4 November 2026. This article is general information and not legal advice.
