The AI Act has two accessibility clauses
Article 16(l) covers high-risk systems, Article 50(5) the notice that tells people they're talking to an AI. The second has applied since 2 August, and it points at laws you may already have to follow.
The AI Act has two accessibility clauses. Two that bind the people who build and deploy AI systems, to be exact. The word also turns up in the recitals, in a rule for the Commission's own database and in the voluntary codes of conduct, and none of those bind anyone building a system.
High-risk systems
Article 16(l) says providers of high-risk AI systems have to "ensure that the high-risk AI system complies with accessibility requirements in accordance with Directives (EU) 2016/2102 and (EU) 2019/882." Those are the Web Accessibility Directive for the public sector and the European Accessibility Act for private services.
High-risk means the list in Annex III: systems that filter job applications, evaluate students, decide on public benefits or score creditworthiness. Most of them put a screen in front of a person who didn't choose the system.
The date moved. The Digital Omnibus, published on 24 July 2026, pushed the high-risk obligations for Annex III systems from 2 August 2026 to 2 December 2027. So 16(l) is law and doesn't apply yet.
What it covers is less clear than it reads. A credit check shown to consumers probably sits inside the EAA's consumer banking services, and a benefits portal sits inside the Web Accessibility Directive. A private employer's hiring tool fits neither directive. Whether 16(l) reaches it anyway, the text doesn't say, and I haven't seen anyone answer it from a primary source.
The notice that says it's an AI
Article 50 is the transparency article: people have to be told when they're interacting with an AI system, deep fakes have to be disclosed, and so on. Paragraph 5 says how, "in a clear and distinguishable manner at the latest at the time of the first interaction or exposure. The information shall conform to the applicable accessibility requirements." This one has applied since 2 August 2026, with no grace period for the chatbot notice.
The Commission's guidelines on Article 50, from 20 July, say what "applicable" means: "Article 50 AI Act does not impose distinct or additional accessibility requirements." The clause is a pointer. If your service falls under the EAA or the Web Accessibility Directive, the notice has to meet them like every other part of the service. If it falls under neither, 50(5) adds nothing.
One level down, the same guidelines get more useful. Audio cues "may support recognition, particularly for visually impaired users, but are not considered sufficient by themselves." A disclosure that only sits in the terms and conditions doesn't count. And the exception for cases where the AI is obvious can't be relied on when the audience includes people with cognitive, physical or mental disabilities.
The Code of Practice on AI-generated content, finalized in June, is more concrete for labels on deep fakes. It asks for "screen-reader compatibility" and "detectability of the icon or equivalent label by assistive technologies," and names EN 301 549 and WCAG 2.1 AA.
Where the notice lives in a chat
The guidelines are about the notice. The engineering is about where it sits in the page.
The notice is text in the DOM, before the first assistant message. A badge image or a tooltip isn't enough, and placement matters more than wording. If focus lands in the input field when the chat opens, a screen reader user starts below the notice and never hears it, so connect the notice to the input with aria-describedby. (Where focus should go is its own post.)
Every AI message needs a marker in text as well. A tinted bubble on its own is WCAG 1.4.1 Use of Color, failing in a new place. The transcript is a log in the ARIA sense, and ARIA 1.2 uses chat logs as its example for role="log", so new messages get announced without moving focus.
Generated images carry their label in the pixels, which is what the Code asks for, and an icon in the pixels is an image. The same words belong in the alt text. Notices that disappear have to stay long enough to read. A toast that fades after three seconds is a notice for some users and nothing for the rest.
The oversight screen
Imagine the person assigned to oversee a hiring system uses a screen reader. Article 14 wants the system to be overseeable, down to "a 'stop' button or a similar procedure." It says nothing about the person. The only route to a stop button that works with a screen reader runs through 16(l), the two directives and the scope question above, and a stop button without an accessible name stops nothing for them.
For chatbots the notice has been required since 2 August, and the quickest check is the obvious one: open the chat with a screen reader running and listen to what comes first.