AI ACT GUIDE
Updated 27 August 2026 · 6 min read
Intercom (Fin) and Article 50: the AI notice to show
Fin and Intercom bots sound human. The site must say so when the chat opens, not only in the terms.
Intercom sells conversational support, often with Fin or other bots. A first name, an avatar and fluent replies do not make the AI “obvious” under Article 50(1). If a visitor might think they are talking to a person, an explicit notice is due at the first interaction.
Putting it only in Intercom Help or at the bottom of the site terms is too late and too easy to miss. A line next to Messenger (“You are chatting with an automated assistant”) is the useful minimum, in the visitor’s language.
Intercom can document its own models. That is not your site register or display log: you are the deployer toward the French and EU public.
Clairia recognises the Intercom script on the homepage, looks for a visible notice, and can attach its own to the widget. Help with compliance, not an Intercom certification.
The path, in order
- 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
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
Re-scan the homepage
Clairia should appear in the findings. This is not a certification: it confirms the script is on the page.
- 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 ↗