Article 50: AI notice required since 2 August 2026 · Compliance checklist
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AI ACT GUIDE

Updated 27 August 2026 · 6 min read

HubSpot Chat and Breeze: is an AI notice required?

HubSpot chat, especially with a bot, is not “obviously human”. The site must show it when the widget opens.

HubSpot Conversations and bots (including Breeze) run on many French marketing sites. A qualification flow that answers on its own falls under Article 50(1) if it is not obvious that it is AI.

A notice in HubSpot’s privacy policy, or in your terms, is too late. Put a readable sentence on the widget (“You are chatting with an automated assistant”) as soon as it opens.

HubSpot documents its features. You document use on your site: register (HubSpot Chat, lead/support use), display log, up-to-date legal pages.

Clairia detects js.usemessages.com and the HubSpot Messages frame on the homepage. This is not a HubSpot audit or legal advice.

The path, in order

  1. 1

    Scan the homepage

    Paste the URL. In under a minute you see whether a known chatbot is present, and whether a notice is visible. With no chatbot there is no /100 score.

  2. 2

    Show the notice next to the chat

    One script line (w.js) sits on Crisp, Intercom, Tidio and known widgets. On Crisp, the sentence is also shown once in the conversation.

  3. 3

    Re-scan the homepage

    Clairia should appear in the findings. This is not a certification: it confirms the script is on the page.

  4. 4

    Let the log run

    Each page load with the script is dated. It is not proof that the chat was opened.

Frequent questions

Who must show the notice: the site or the chat vendor?
The visitor is talking to your site. The vendor (Crisp, Intercom, Tidio…) provides the tool. The site must inform, at the first interaction.
Is a notice in the terms or legal notice enough?
No. Too late and too easy to miss during the chat. Article 50 requires clear information at the latest at the first interaction.
How do you prove the notice was shown?
A useful file: a register (tool, vendor, use), a dated log of script loads, homepage scans. A /100 score is not proof.

General information, not legal advice.

Official reference: European Commission Article 50 guidelines ↗

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