AI Disclosure to Clients: Art. 50 Template for Professional Firms

Transparency about AI use has become a regulatory obligation — not a courtesy or a differentiating element, but a minimum requirement for compliant operation. With the AI Act fully applicable to deployers and national implementing laws in force across EU member states, every professional who uses AI in managing client matters has an obligation to inform them.

This article explains what the regulation requires, where the disclosure should be inserted, and provides a ready-to-adapt template.

What Art. 50 AI Act requires

Art. 50 of Regulation (EU) 2024/1689 (AI Act) establishes transparency obligations for two categories. Note: Art. 50 will be fully applicable from 2 August 2026 (Art. 113 AI Act). However, for Italian professionals, the client disclosure obligation is already in force since 10 October 2025 under Art. 13 of Law 132/2025.

1. AI systems that interact with natural persons: those who deploy AI systems designed to interact directly with people (chatbots, voice assistants, automated response systems) must inform their interlocutor that they are interacting with an AI — except in cases where this is obvious from the context.

2. Content generated or manipulated by AI: those who use AI to generate or manipulate content (texts, images, audio) that can reasonably mislead as to authenticity must mark such content as AI-generated.

For an accountant, a lawyer or an HR consultant, the practical application of Art. 50 concerns above all the second category: documents, opinions, reports, analyses drafted with AI support that are delivered to clients.

Art. 50 does not prohibit the use of AI. It requires that the use be transparent.

What national implementing laws add

National laws implementing the AI Act across EU member states go further on one specific point: the written disclosure obligation for professionals.

National implementing provisions typically require regulated professionals and those carrying out regulated or de facto reserved professional activities to:

• Inform the client in writing when AI systems are used in carrying out the professional mandate.
• Specify the AI systems used and the activities for which they are employed.
• Describe the manner of human oversight of AI outputs.
• Indicate the client's rights in this regard, including the right to request additional information.
• Retain documentation relating to AI use for a reasonable period as a matter of best practice and professional diligence.

The disclosure obligation applies from the moment AI is used on the client's matter — not from the signature of the contract. For clients with ongoing engagements at the point national laws came into force, the disclosure should be provided retroactively as soon as possible.

Template AI disclosure

The text below is a complete model, already structured to comply with the requirements of both levels of regulation. Fields in square brackets must be replaced with the firm's specific details.

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Dear [CLIENT NAME],

We are writing to inform you that in carrying out the services provided for under our professional engagement, [FIRM NAME] uses artificial intelligence (AI) tools for [ACTIVITY DESCRIPTION: e.g. "drafting document templates", "analysis of regulatory data", "regulatory and case-law research"].

The AI tools currently in use are: [LIST OF TOOLS: e.g. Microsoft Copilot, ChatGPT Enterprise, Kira Systems]. These tools are selected on the basis of their compliance with Regulation (EU) 2016/679 (GDPR) and have adequate data processing agreements in place.

Every output generated by AI systems is subject to review and oversight by a qualified professional of the Firm, who assumes full professional responsibility in accordance with the ethical rules of [RELEVANT PROFESSIONAL BODY]. The use of AI supports professional activity without replacing it.

You have the right to request at any time specific information on the use of AI in your matter, including: the systems employed, the activities for which they are used, and the manner of human review. Such information is provided within 10 working days of written request. You also have the right to object to the use of AI on your personal data, within the limits permitted by applicable law and compatible with the Firm's operational methods.

Documentation relating to the use of AI is retained for a period of [5] years as a matter of professional best practice and in line with the firm's general document retention policy.

For any queries or requests, please contact us at [EMAIL] or on [TELEPHONE].

Yours sincerely, [FIRM NAME AND SIGNATURE] [DATE]

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Where to include the disclosure

There are three methods of delivery, each with different characteristics:

Option A — Integrated in the engagement letter (recommended) The disclosure is included as a specific article in the engagement letter, before the liability section. The client receives it, reads it and signs it along with the rest of the contract. This is the most defensible form: the client has explicitly accepted the document that contains the disclosure.

Option B — Separate attachment to the engagement letter The disclosure is attached as a separate document ("Annex A — AI Disclosure") that the client signs separately. Useful if the standard engagement letter cannot be modified in the short term.

Option C — Standalone email for existing clients For clients with already-ongoing engagements, email is the quickest solution. Evidence of sending must be retained and, if possible, confirmation of receipt obtained. A simple "Received and noted" from the client is sufficient.

How and when to deliver it

Timing: the disclosure must precede the start of AI use on the client's matter — it cannot be provided retrospectively as a formal obligation.

• For new engagements: at the signing of the engagement letter.
• For clients with existing engagements when implementing laws came into force: as soon as possible, ideally at the first contact thereafter.
• For each new AI tool adopted: update the disclosure and notify affected clients.

Form: written — paper or digital. Email is explicitly accepted by the regulations, provided it is retained.

Evidence of delivery: always retain evidence of delivery. Practical options:

• Email with read receipt or request for a confirmation reply.
• Certified email (provides automatic receipt).
• Client's signature on a paper copy.
• Copy of the signed engagement letter that includes the AI clause.

What NOT to do

These are the most common mistakes that make the disclosure ineffective or non-compliant:

• Generic boilerplate without specific tools: "We may use AI tools" is not sufficient. The regulations require identification of the systems in use.
• No mention of human oversight: the disclosure must specify that a professional reviews and assumes responsibility for the outputs. Without this element, one of the key requirements is missing.
• Right to object omitted: the client must know that they can request information and, within the limits of operational compatibility, object to the use of AI on their data.
• Retention period not specified: as a matter of professional best practice, AI documentation should be retained for a reasonable period (e.g. five years). The disclosure should reference the firm's retention policy.
• Retrospective delivery: providing the disclosure after AI has already been used on client matters does not cover the prior period and can be challenged.

The immediate practical step

If your firm already uses AI tools — even just Copilot in emails or ChatGPT for drafts — the disclosure is already due. The immediate practical step is:

1. Do an inventory of AI tools in use (which ones, for which activities).
2. Verify that each has an adequate DPA with its supplier.
3. Adapt the template with the firm's specific details.
4. Send the disclosure to all active clients, retaining evidence of sending.
5. Integrate the clause in the standard engagement letter template for all new engagements.

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In our guides collection you will find the complete AI disclosure template, already formatted in Word and PDF, with variants for accountants, lawyers and HR consultants — ready to adapt in 15 minutes.

Download the free template — Explore the AI Act Ready service

For a complete understanding of the regulation that makes this disclosure mandatory — including deadlines, risk categories and the full scope of deployer obligations — read our AI Act guide.