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EU AI Act Disclosure for MetaMask Agent Wallet

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Document Record

What it is

Consensys discloses that MetaMask Agent Wallet features are AI-driven systems under the EU AI Act, and requires users to acknowledge they are interacting with an automated system rather than a human when using those features.

This analysis describes what MetaMask's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision constitutes a transparency disclosure required under the EU AI Act for AI systems interacting with users, and establishes the contractual acknowledgment that users are on notice of the automated nature of Agent Wallet features at the point of use.

Interpretive note: Whether the contractual acknowledgment mechanism fully satisfies EU AI Act transparency and conformity assessment requirements depends on the specific risk classification of the Agent Wallet features, which is not established in the document.

Recent Activity

This document changed recently

Medium Jul 1, 2026

The updated terms explicitly state that UK, EU, and EEA consumers retain statutory consumer protection rights that cannot be limited or excluded by the agreement, and that applicable local law prevails in the event of conflict with these terms. This adds clarity to the legal framework but does not change substantive protections for those users. The terms also clarify that mUSD is a third-party digital asset not issued by Consensys, treating it as a third-party service subject to the agreement's limitations on Consensys' responsibility for third-party services.

View change record →

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users of MetaMask Agent Wallet features are required to acknowledge that those features are AI-driven automated systems, not human agents, as part of EU AI Act compliance. This acknowledgment is incorporated into the Agreement as a binding representation by the user.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Certain features of the Offerings (i.e. MetaMask Agent Wallet) are powered by artificial intelligence and machine learning technologies. In accordance with applicable laws, including the EU AI Act, we identify these features as AI-driven systems. By using these specific features, you acknowledge that you are interacting with an automated system rather than a natural person.

Excerpt from MetaMask's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly cites the EU AI Act as the applicable regulatory basis for the AI disclosure requirement. The EU AI Act imposes transparency obligations on providers and deployers of AI systems that interact with natural persons, including disclosure that the interaction is automated. Enforcement is assigned to EU member state market surveillance authorities and the European AI Office for certain high-risk system categories. (2) GOVERNANCE EXPOSURE: Medium. The disclosure is explicit and directly references the EU AI Act, which reduces regulatory risk for EU/EEA users. However, the adequacy of a contractual acknowledgment as the sole mechanism for EU AI Act compliance, and whether the Agent Wallet features require conformity assessment as a high-risk AI system, are questions that require legal review against the specific EU AI Act classification criteria. (3) JURISDICTION FLAGS: EU/EEA jurisdictions are the primary exposure. The disclosure may also engage emerging AI transparency requirements in the UK (post-Brexit AI regulatory framework) and US state-level AI disclosure legislation (including California's proposed AI transparency requirements). Non-EU users who access Agent Wallet features may not benefit from the same disclosure protections if only EU AI Act compliance is pursued. (4) CONTRACT AND VENDOR IMPLICATIONS: Business accounts deploying MetaMask Agent Wallet in their own user-facing services should assess whether this Consensys-level AI disclosure is sufficient for their own EU AI Act obligations as deployers, or whether additional disclosures to their end users are required under the EU AI Act's deployer accountability framework. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the Agent Wallet features require classification as a high-risk AI system under EU AI Act Annex III, whether conformity assessment procedures have been completed, and whether the contractual acknowledgment mechanism satisfies the EU AI Act's transparency requirements as implemented in each member state. The interaction with the user indemnification and AI Agent responsibility clauses should also be reviewed.

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Provision details

Document information
Document
MetaMask Terms of Use
Entity
MetaMask
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015127
Document ID
CA-D-00279
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fbc3e940d542d736f423bed59d696fff5bef4265893e8cc2ffd8581c3ba58f1d
Analysis generated
July 9, 2026 07:13 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: MetaMask
Document: MetaMask Terms of Use
Record ID: CA-P-015127
Captured: 2026-07-09 07:13:37 UTC
SHA-256: fbc3e940d542d736…
URL: https://conductatlas.com/platform/metamask/metamask-terms-of-use/provision/CA-P-015127/eu-ai-act-disclosure-for-metamask-agent-wallet/
Accessed: July 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does MetaMask's EU AI Act Disclosure for MetaMask Agent Wallet clause do?

This provision constitutes a transparency disclosure required under the EU AI Act for AI systems interacting with users, and establishes the contractual acknowledgment that users are on notice of the automated nature of Agent Wallet features at the point of use.

How does this clause affect you?

Under this clause, users of MetaMask Agent Wallet features are required to acknowledge that those features are AI-driven automated systems, not human agents, as part of EU AI Act compliance. This acknowledgment is incorporated into the Agreement as a binding representation by the user.

Is ConductAtlas affiliated with MetaMask?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by MetaMask.