An AI transparency statement for customer service must include, at a minimum: which AI systems are used, what they are used for, whether customers are speaking with an AI or a human, what data is processed, and how customers can object or reach a human representative. This information is not only a matter of good service but also a legal requirement under the EU AI Act. In this article, we answer the most frequently asked questions about exactly what an AI transparency statement entails and how you can practically draft one for your customer service environment. Would you like to learn more about how AI can be used in customer service? Read on to learn more about AI-driven intelligence.
What is the minimum information that an AI transparency statement must include?
An AI transparency statement must, at a minimum, describe which AI systems you use, the purpose of each system, whether and when customers interact with AI, what personal data is processed, how long that data is retained, and how customers can contact a human representative or object to automated decisions.
In practical terms, this means that for every AI system in your customer service department, you should define the following elements:
- System Identification: What is the system, who developed it, and what role does your organization play (as a user or provider)?
- Purpose and Function: What is the system used for—for example, routing calls, answering frequently asked questions, or sentiment analysis?
- Notice to the customer: When and how is the customer informed that he or she is communicating with an AI system?
- Data Processing: What personal data is processed, on what legal basis, and how long is it retained?
- Customer Rights: How can a customer speak with a human representative, appeal a decision, or request an explanation of an automated outcome?
A transparency statement that simply states in general terms, “We use AI,” is insufficient. Customers need to understand exactly what happens during their interactions and how AI affects the outcome of their inquiry or complaint.
What does the EU AI Act say about transparency in customer service?
The EU AI Act requires organizations that use AI in customer service to actively inform customers when they are communicating with an AI system. This applies specifically to systems designed to interact with people, such as chatbots and voice assistants. The disclosure that you are speaking with an automated system must be clear and understandable before or at the start of the conversation.
The AI Act distinguishes between different risk levels. Most customer service AI falls into the “limited risk” category, which is subject to less stringent transparency requirements. However, systems that make decisions with significant consequences for customers—such as denying a request or prioritizing a complaint—may be classified as “high risk.” Stricter requirements apply to those systems, including the customer’s right, under Article 86, to request an explanation of the factors that determined a decision.
Practical implications for 2026: The compliance requirements for high-risk systems covered by Annex III will become enforceable on August 2, 2026. Organizations that use AI—for example, to prioritize customer inquiries or assess customer profiles—would be wise to start keeping a register of all AI systems now and to define their roles within those systems. The AI literacy requirement—which mandates that employees understand how the AI systems they use work—has been in effect since February 2025.
How does an AI transparency statement differ from a privacy statement?
An AI transparency statement and a privacy statement overlap to some extent, but serve fundamentally different purposes. A privacy statement explains how you handle personal data in accordance with the GDPR. An AI transparency statement explains how your AI systems work, what role they play in customer interactions, and what rights customers have regarding automated decisions.
The difference lies in the focus:
- Privacy Statement: This covers data. What data do you collect, why, on what legal basis, how long do you retain it, and who should you contact to request access or deletion?
- AI Transparency Statement: Covers systems and decisions. Which AI systems do you use, for what purposes, how do they affect the customer experience, and how can a customer challenge an automated decision or request human assistance?
In practice, it is advisable to combine both documents or to explicitly cross-reference them. When an AI system processes personal data—which is almost always the case in customer service—both statements apply. A DPIA (Data Protection Impact Assessment) may be required when AI systems process personal data on a large scale or engage in profiling.
How do you explain the use of AI without technical jargon?
You explain how AI is used without technical jargon by focusing on the customer’s experience, not on how the system works. Describe in plain language what the AI does during the interaction, why that’s helpful for the customer, and what the customer can do if he or she would prefer to speak with a human.
A few practical guidelines:
- Use the term “digital assistant” or “automated system” instead of terms such as “large language model” or “NLP engine.”
- Explain what the system does for the customer: “Our digital assistant answers frequently asked questions right away, so you don’t have to wait.”
- Be honest about limitations: “For complex questions, you’ll be transferred to a representative.”
- Always provide a clear way out: “You can press ‘0’ or say ‘representative’ at any time to speak with a person.”
- Avoid double negatives and long sentences. Write as if you were explaining it to a customer over the phone.
The goal of clear language is not only compliance, but also trust. Customers who understand what is happening are less likely to be suspicious and view the AI interaction as a form of good service rather than an obstacle.
Where should an AI transparency statement be visible to customers?
An AI transparency statement must be visible at the moment the customer interacts with an AI system. This means: at the start of a chat conversation, in the IVR greeting during a phone call, on the webpage where a chatbot is active, and as a separate section in your privacy policy or terms of service.
Visibility has two dimensions: active reporting and easily accessible documentation.
Active disclosure means informing the customer at the time of contact. A chatbot that does not identify itself as AI does not meet the transparency requirements of the EU AI Act. A simple opening line such as “You are speaking with a digital assistant from [organization name]” is already a good first step.
“Accessible documentation” means that the full AI transparency statement is available on the website, preferably via a direct link in the chat interface or in the confirmation email sent after a customer interaction. Customers who want to know more about how AI affects their interaction should be able to find this information without having to search for it.
For organizations that use multiple channels—such as phone, chat, WhatsApp, and email—it is advisable to specify which AI systems are active on each channel. This prevents confusion and makes the statement practically useful.
When should an AI transparency statement be updated?
An AI transparency statement must be updated as soon as there is a change in the AI systems you use, the way they are used, the data they process, or the rights that customers have. Examples include introducing a new AI system, expanding an existing system to a new channel, or changes in legislation.
Specific situations in which an update is required or strongly recommended:
- You are introducing a new AI system into your customer service process.
- An existing system is being enhanced with new features that affect customer interactions.
- You switch to a different supplier for an AI component.
- Legislation changes, such as the entry into force of new obligations under the EU AI Act on August 2, 2026.
- An incident has occurred in which AI made an incorrect or harmful decision.
It is advisable to review the AI transparency statement at least once a year, even if there is no immediate reason to do so. Record the date of the last update in the document itself so that customers and regulators can see that the statement is up to date. Organizations that maintain an internal AI registry can link the transparency statement to that registry for a more efficient update process.
How Pegamento Helps Ensure AI Transparency in Customer Service
At Pegamento, we understand that AI transparency is not only a legal obligation but also an opportunity to strengthen customer trust. We help organizations use AI in a responsible and understandable way within their customer service environment. Our approach is concrete:
- Understanding Your AI Landscape: We help you create an overview of all AI systems in use in your customer interactions, including their roles and risk classifications.
- Transparency Built In: Our Agentic AI for customer service is designed with clear customer communication as the standard, not an afterthought. Customers always know when they’re interacting with a digital assistant and how to reach a human agent.
- Everything under one roof: From AI implementation to documentation and management, you have a single point of contact for the complete package. No silos, no complex supplier management.
- Customized solutions using standard building blocks: We combine proven modules to create a solution that fits your organization, industry, and customer contact volume—without the need for costly customization.
- Compliance-focused: We are ISO 27001 (information security), ISO 9001, and ISO 26000 certified, and we actively monitor developments related to the EU AI Act.
Would you like to know how your organization can use AI transparently and effectively in customer service? Contact us, and we’d be happy to help you explore your options.
Frequently Asked Questions
Does the AI transparency statement also apply to small organizations with only one chatbot?
Yes, the transparency requirements under the EU AI Act apply regardless of the size of your organization or the number of AI systems you use. Even if you only use a simple FAQ chatbot, you are required to actively inform customers that they are communicating with an automated system. Fortunately, for small organizations, the practical burden is limited: a short opening sentence in the chat interface and a paragraph in your privacy policy may be sufficient for systems with a low-risk profile.
What is the biggest mistake organizations make when drafting an AI transparency statement?
The most common mistake is drafting a statement that is too generic, such as ‘we use AI technology to improve our services,’ without specifying which systems are in use, what they are used for, and what rights the customer has. Such vague wording does not meet the requirements of the EU AI Act and tends to inspire mistrust rather than trust. A good transparency statement is system-specific, understandable to the average customer, and always includes a concrete way to contact a human.
How do I address third-party AI systems in my transparency statement?
If you use AI systems from third-party providers, your organization remains responsible for transparency toward your customers. In your statement, you must specify which third parties provide AI components and what role they play in the processing of customer data. Specify in your supplier contracts what documentation the supplier must provide so that you can keep your own transparency statement accurate and up to date. Also verify that the supplier itself complies with the obligations the EU AI Act imposes on providers.
Do customer service employees need to be aware of the content of the AI transparency statement?
Absolutely, and this is even a legal requirement. The AI literacy requirement, which takes effect in February 2025, mandates that employees working with AI systems understand how those systems function and how they impact customer interactions. In practice, this means that customer service representatives must know what the transparency statement says, how to inform customers about AI usage, and how to properly handle an escalation to a human agent. Therefore, include the statement in your onboarding and training materials.
Can I use a single AI transparency statement for all channels, or do I need one for each channel?
You can use a single overarching document as a basis, but it is strongly recommended to specify for each channel which AI systems are active and how customer notifications are handled. A chatbot on your website, a voicebot in your IVR, and an automated email system each have a different form of interaction and may also involve different data processing activities. By adding channel-specific sections to your main statement, the document remains both compliant and practical for customers who want to understand exactly what happens during their specific point of contact.
What should I do if an AI system has made an erroneous decision that has harmed a customer?
Notify the customer as soon as possible, explain what went wrong, and offer a correction or compensation. Document the incident in your internal AI log, including the cause, the consequences, and the corrective actions taken. Depending on the severity of the situation, reporting the incident to the Dutch Data Protection Authority or another regulatory body may be required. Also use the incident as an opportunity to review your AI transparency statement and verify whether the customer rights described—such as the right to challenge an automated decision—are actually enforceable in practice.
How do I measure whether my AI transparency statement is effective and actually reaches customers?
You measure effectiveness on two levels: reach and understanding. For reach, you can track how many customers open the statement via direct links in your chat interface or confirmation emails. For understanding, customer feedback is more valuable: ask in customer satisfaction surveys whether customers knew they were communicating with an AI system and whether they knew how to reach a human agent. If a significant portion of your customers indicate they didn’t know this, that’s a sign that you need to improve your active notifications or the visibility of your documentation.
