A scope document for an outsourced customer-service chatbot needs two items of its own. One is the spot where users learn, on first contact, that they are talking to AI. The other is the route that hands a stuck conversation to a person. For chatbots built on generative AI, Korean law already requires the notice. The handover route is now law in the EU, starting with financial contracts. In the UK, a consumer charity is pushing to extend that route to energy and telecoms.
Online Financial Contracts Now Carry a Right to a Person
EU Directive 2023/2673 rewrote the rules for financial services contracts concluded at a distance. Its new Article 16d(3) covers traders who use online tools. In that case the consumer must be able to request and obtain human intervention at the pre-contractual stage and, in justified cases, after the contract is signed. Member States have to guarantee this right. The human intervention must happen in the same language as the pre-contractual information[1]. The directive's recitals explain that the right is aimed at fully automated online interfaces such as chatbots, robo-advice and interactive tools[1].
Member States had to adopt national rules by December 19, 2025 and apply them from June 19, 2026[1]. Ireland signed the rules into law in July 2026. Tánaiste Simon Harris named the practical changes consumers would notice: "the right to speak to a real person instead of relying solely on an automated system, clearer information before making a decision, or an easier way to cancel an eligible contract"[2].
14% of Those Who Could Not Reach a Person Gave Up
Citizens Advice, the UK advice charity, has told providers of essential services such as energy, banking, phone and internet to stop leaning on AI chatbots for customer care. Its demand is a guaranteed right to talk to a human[3].
According to the charity's research, chatbots wasted time, caused stress and delayed problem solving for more than half of users. Almost half of the people who had to use one found it unhelpful. Some concluded the chatbot seemed rigged to "make me give up"[3].
Among people who found it difficult or impossible to reach a human about a problem with an essential service, 49% felt stress or frustration, 27% felt powerless, 44% experienced delays in getting it resolved, and 14% gave up on resolving it altogether[3]. In a July 2026 poll of UK adults carried out for Citizens Advice, only 20% named chatbots as their preferred way to get in touch. Phone calls, email and instant messaging all came out ahead[3].
When the online route breaks, the time involved balloons. Submitting an energy meter reading to correct a wrong bill takes less than an hour online if the systems work. For someone without good digital access, doing it offline took as long as six weeks[3].
"Going round in circles with a chatbot isn't just annoying, it can be a blockade to essential services," said Tom MacInnes, policy director at Citizens Advice. "There's a role for chatbots, but the quiet erosion of face-to-face and telephone services is letting too many people fall through the cracks," he added[3]. A UK government spokesperson replied: "Businesses have a legal obligation to provide contact information in a manner which is clear and easily accessible"[3].
Korea's Law Stops Short of a Human Handoff
Korea's Framework Act on the Development of Artificial Intelligence and the Establishment of a Foundation for Trust (the AI Basic Act) has been in force since January 22, 2026. Article 31(1) places one duty on businesses that intend to offer a product or service using high-impact AI or generative AI. They must tell users in advance that the product or service operates on the basis of AI[4].
What the article requires is notice. Article 31 contains no right to ask for a human agent. The specifics of how to give notice and how to label are left to a presidential decree[4].
Two Items the Scope Document Should List Separately
Turn the three sets of rules into chatbot design and two places need their own line.
The first is the moment a user meets the chatbot. If you launch a chatbot built on generative AI in Korea, this is where users have to be told in advance that it runs on AI[4]. Because the details of that notice are left to a presidential decree, it is safer to make the notice text replaceable without touching code.
The second is the route to a person when a conversation stalls. For a company selling financial products online in the EU, that route is a legal obligation[1]. Reading the article as a design spec adds two more requirements. If the pre-contractual information was given in German, the human conversation has to happen in German too. And the route has to stay available on screens after the contract is signed[1].
What those two items add to the build, and what the bot costs to run each month, is covered separately in A Chatbot Arrives With a Meter Attached.
What Still Needs the Source Text
The Guardian's report does not give the sample size or method of the Citizens Advice research, and we could not find the charity's original report. Nor could we confirm whether the UK government plans any formal response to the demand.
Two questions remain on the Korean side. How the AI Basic Act's enforcement decree sets out notice for customer-service chatbots has to be checked against the decree itself. Whether Korean financial regulation separately requires chatbot support to connect customers to a human agent is something this research could not settle.
We Write Down the Handover Rules Before the Screen List
When Weple takes on a customer-service chatbot as AI feature work, two pages get written before any screen is drawn. The first sets out the sentence that tells users they are talking to AI and where it appears. The second lists which conversations go to a person and who picks them up. For a financial service with European customers, the language used for pre-contractual information goes on that page as well. How we count the work for a quote is on the pricing page. If a chatbot is already live, the reply it gives when someone types "agent" is the first thing we will ask to see.
References
[1] European Parliament and Council of the European Union. Directive (EU) 2023/2673 of the European Parliament and of the Council of 22 November 2023 amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC. EUR-Lex, 2023-11-22.
[2] Stephen McDermott. Consumers can request to speak to human instead of chatbot under new financial services rules. TheJournal.ie, 2026-07-03.
[3] Robert Booth. Stop relying on AI chatbots for customer care, UK banks and energy firms told. The Guardian, 2026-09-21.
[4] Korea Law Information Center. Framework Act on the Development of Artificial Intelligence and the Establishment of a Foundation for Trust, Article 31 (Obligation to Ensure AI Transparency) (in Korean).
In a similar spot
Send us where things stand and we reply with the scope and the price within 24 hours.