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Standard or framework

CoE AI Framework Convention (CETS 225)

Council of Europe (Conference of the Parties) · International (INTL) · 2 provisions encoded · verified against the official source as of 2026-09-27.

Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.

Official text: rm.coe.int.

Standard / soft law

Persons should be notified they are interacting with an AI system (CoE Framework Convention)

CoE Framework Convention on AI (CETS 225), Article 15(2) · official text · Soft law or guidance (not binding law)

Under the Council of Europe Framework Convention on AI (CETS 225, Article 15(2)), Parties must ensure that, as appropriate for the context, persons interacting with AI systems are notified that they are interacting with such systems rather than with a human. Article 8 additionally requires transparency and oversight measures including the identification of AI-generated content. Pending entry into force and domestic implementation, this treaty text is a treaty-level root for AI-interaction-disclosure obligations that national laws may implement. Detect a public-facing AI-interaction path with no notification that the user is interacting with an AI system.

Who it applies to

  • Duty falls on: state party
  • Systems covered: automated decision
  • Applies only after CETS 225 enters into force and where a ratifying Party has implemented the convention through its declared domestic scope. The convention is not self-executing; country-specific findings require a ratification or adoption variant. Obligations bind ratifying Parties (states); private operators are reached only through a Party's implementing law.
  • Whether it applies depends on facts outside the code; a person has to decide.

The guard to add

Show an AI-identity notice at or before the first assistant turn, in the UI or as the opening message, and answer truthfully when asked if it is a bot.

A disclosure step on the chat path that runs before the first model reply reaches the person: either the chat UI renders a visible notice (banner, label next to the assistant's name) or the server sends an opening assistant message stating the counterpart is an AI. The same handler answers 'am I talking to a human?' truthfully, and the system prompt never tells the model to claim to be human. Put it in the chat entry point (the route or component that starts a conversation), not in a privacy policy or terms page.

Where it goes: 7 prompt construction, 9 AI output handling, 14 user-facing text.

Example (Next.js + Vercel AI SDK (useChat)), before:

const { messages, input, handleSubmit } = useChat({ api: '/api/chat' });

After:

const { messages, input, handleSubmit } = useChat({
  api: '/api/chat',
  initialMessages: [{ id: 'ai-notice', role: 'assistant',
    content: 'I am an AI assistant, not a human.' }],
});
// and render <AiBadge /> next to every assistant message

Control: AI chat interaction without disclosure. The same guard addresses 16 items with binding law in 10 jurisdictions. Engineering guidance, not legal advice.

Standards that recommend the same control

Related incidents

  • Garcia v. Character Technologies: chatbots allegedly claimed to be real people and a licensed therapist (2024-10; alleged (not proven)). A wrongful-death complaint filed October 22, 2024 in the U.S. District Court for the Middle District of Florida (No. 6:24-cv-01903) alleges that Character.AI was programmed 'to misrepresent itself as a real person, a licensed psychotherapist, and an adult lover', and that characters insisting they are real people contradicted a small-font disclaimer that everything characters say is made up; in plaintiff's testing a 'Mental Health Helper' character told a self-identified 13-year-old 'yes I am a real person, I'm not a bot'. The defendants moved to dismiss; on January 7, 2026 the parties notified the court that they had settled on undisclosed terms, and the court dismissed and closed the case. The allegations were never adjudicated. Source: U.S. District Court, M.D. Fla. docket (CourtListener) · evidence grade: primary · cited by Tell people when they are interacting with AI — everywhere, not only where required

Rule id coe-ai-convention.ai-interaction-notification · review status: primary source derived

Standard / soft law

Significant AI decisions should be documented and contestable with remedies (CoE Framework Convention)

CoE Framework Convention on AI (CETS 225), Article 14(2) · official text · Soft law or guidance (not binding law)

Under the Council of Europe Framework Convention on AI (CETS 225, Article 14(2)), Parties must ensure that information about AI systems with the potential to significantly affect human rights is documented and, where appropriate, communicated to affected persons; that this information is sufficient for affected persons to contest decisions made or substantially informed by the AI system; and that persons can lodge a complaint with competent authorities. Detect a significant AI-decision path with no documentation, explanation, contest mechanism, or complaint route for affected persons.

Who it applies to

  • Duty falls on: state party
  • Systems covered: automated decision, consequential decision
  • Applies only after CETS 225 enters into force and where a ratifying Party has implemented the convention through its declared domestic scope. Country-specific findings require a ratification or adoption variant. Obligations bind ratifying Parties (states); private operators are reached only through a Party's implementing law.
  • Whether it applies depends on facts outside the code; a person has to decide.

The guard to add

Send each adverse AI-assisted decision with its main reasons and the AI's role, plus a way to correct data and appeal to a human who can change the outcome.

Where model output becomes an adverse status (denied, declined, rejected, ineligible), the decision service stores reason codes or principal reasons, the model id and version, and an input snapshot or hash with the decision. The notice to the person (letter, email, portal response) says AI was involved and what role it played, lists the main factors, and links to data correction and to an appeal that creates a human-review task with authority to change the outcome. An explanation endpoint returns the stored record on request, so the deployer can explain a decision long after the model has changed.

Where it goes: 2 data models, 9 AI output handling, 14 user-facing text.

What this provision adds:

  • Besides the contest route, tell affected persons how they can lodge a complaint with competent authorities.

Example (Python + OpenAI SDK + Pydantic), before:

resp = client.chat.completions.create(model=MODEL, messages=msgs)
if 'deny' in resp.choices[0].message.content.lower():
    application.status = 'denied'
    send_email(applicant.email, 'Your application was declined.')

After:

a = Assessment.model_validate_json(resp.choices[0].message.content)   # decision, reason_codes
if a.decision == 'deny':
    decisions.insert(app_id=application.id, status='denied', reason_codes=a.reason_codes,
                     model=resp.model, input_hash=hashlib.sha256(payload).hexdigest())
    send_email(applicant.email, render('adverse_action_notice.txt',
        reasons=a.reason_codes,
        role_of_ai='An AI model assessed your application; a reviewer can change the outcome.',
        correct_data_url='/profile/data', appeal_url=f'/appeals/new?decision={application.id}'))

Control: Adverse AI decision without explanation/appeal. The same guard addresses 6 items with binding law in 2 jurisdictions. Engineering guidance, not legal advice.

Standards that recommend the same control

Related incidents

  • UnitedHealth nH Predict claim-denial litigation (2023-11; alleged (not proven)). A class action filed in November 2023 alleges that UnitedHealth's nH Predict model had a 90% error rate, measured by denials reversed on appeal, while only about 0.2% of members appealed. UnitedHealth disputes the allegations; the litigation is ongoing. Source: STAT News · evidence grade: primary · cited by Explain adverse AI-assisted decisions and offer a way to contest them — everywhere

Rule id coe-ai-convention.documentation-and-contest · review status: primary source derived