The AI Act doesn't only concern companies that develop AI models. It also concerns those that deploy them, and in the CRM world, that's almost everyone. As soon as a chatbot responds to a customer, a virtual assistant qualifies a lead, or a conversational agent interacts with your contacts, Article 50 applies.
Most CRM teams haven't yet mapped their exposure. And just like the email tracking pixel in July, neither Adobe Campaign nor Salesforce do anything natively to help you comply.
Article 50 of the EU AI Act (Regulation (EU) 2024/1689) imposes transparency obligations on providers and deployers of AI systems that interact with users in the EU.
A commonly misunderstood point: the AI Act does not require you to label every marketing email written with AI assistance. A commercial email is neither a deepfake nor content published "to inform the public on matters of public interest". What is mandatory is the declaration of AI systems in direct interaction with your contacts.
The question to ask for each tool in your stack: does a customer or prospect interact directly with this system without knowing it's an AI?
Adobe Campaign Classic and Campaign v8 offer no native functionality for managing Article 50 compliance. No AI declaration setting, no automatic disclosure template, no audit of AI interactions in workflows. If you use third-party AI modules connected to Campaign, responsibility for the declaration remains entirely yours.
Salesforce has integrated Einstein across virtually all its products, engagement prediction, content generation, lead scoring, Einstein Bots. None of these modules automatically handle the Article 50 declaration for you. The compliance of bots and agents deployed to your customers remains your responsibility.
Article 50 responsibility falls on the deployer, that's you, not Adobe, not Salesforce. Compliance is a project your teams must drive.
The good news: unlike pixel tracking, Article 50 compliance on chatbots is technically straightforward. A disclosure in the first message of a bot is not six weeks of development. It's a configuration.
The real difficulty is organisational. Who is responsible for this mapping in your organisation? The marketing team that uses the bots? The IT department that hosts them? The DPO? As I described in my article on the organisational crisis of pixel tracking, regulation doesn't create problems, it makes existing ones visible.
The question to ask in your team meeting this week: "Which tools in our CRM interact directly with our contacts without identifying themselves as AI?" If nobody can answer within five minutes, you have your priority.
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