Unlike national customer service regimes, which apply to a function, the AI transparency duty applies to any system interacting directly with natural persons — regardless of sector, size or legal nature.
Size
02.08.2026Article 50 appliesin all 27 Member States
02.12.2026end of grace periodpre-existing systems
28.06.2025accessibility enforceablesupport services included
02.02.2025emotion recognition prohibitedno transition
Categories of audience
| Category | Legal position | Verified size | Priority |
|---|---|---|---|
| Outsourced customer service providers | Performing party, with contractual liability of its own and liability as a data processor | Concentrate 83 % of the sector’s seats; 74.7 % of operations are outsourced | Second |
| In-house operations in retail, healthcare, industry and services | Obliged as a trader in the consumer relationship | 25.3 % of operations are in-house | Second |
| Technology vendors, integrators and training providers | Interested, and exposed through the systems they supply | Directly affected by the article 50 transparency duty | Third |
| Financial services and insurance | Obliged, with conduct supervision layered on top | Covered by the Spanish regime as a service of general interest | First |
| Providers of essential public services — energy, water and waste | Obliged, with reinforced application | Portugal: 39 electricity and gas suppliers; 352 water and waste operators | First |
Sources
Quantitative data comes from the Portuguese Contact Centre Association, from the study it commissioned from Deloitte, from Eurostat and from the sector regulators cited on each page. Figures drawn from different sources are not additive, and the notes indicate where the series diverge. [Data not confirmed in an official source is marked in square brackets and italics.]
Locate your organisation
The first question is not which service you need, but which category your organisation falls into and what follows from that.