French town halls: where to start before handing phone reception to an AI

In its first clarifications on deploying generative AI (July 2024), the CNIL, France’s data protection authority, recommends starting from a concrete need, drawing up a list of authorised and prohibited uses, and not overlooking the limits of these systems. For a town hall, this means writing down in black and white what the agent handles, for example opening hours, routine procedures and message-taking, and what stays with staff and elected officials: individual situations, complaints, anything that commits the municipality.

The questions themselves are easy to list by listening to the switchboard for a few weeks. What matters here is the decision on scope, taken and owned by the municipality.

An agent answers from what it is given: the municipality’s website, council decisions, opening hours, instructions. Appoint a person responsible for this content and a schedule for updates, otherwise the agent will announce summer opening hours in November.

On personal data, the CNIL points out that all public bodies, whatever their size, must appoint a data protection officer, and that pooling one, with the intermunicipal authority or a management centre (centre de gestion), suits the smallest local authorities. Involve them from the scoping stage. People must be informed at the time of collection: identity of the controller, purposes, legal basis, recipients, retention period, rights, contact details of the data protection officer. The CNIL recommends concise, layered information; for the phone, it mentions information given by the person answering or by a recorded message, with the option of obtaining more detailed information. In practice: a short announcement at the start of the call, the full notice on the website.

According to the European Commission, Article 50 of the Artificial Intelligence Act has applied since 2 August 2026. The “digital omnibus” regulation on AI, signed on 8 July 2026, postponed the obligations for high-risk systems to 2 December 2027 and 2 August 2028, but not this information obligation; the Commission mentions only one grace period, until 2 December 2026, for marking generated content (paragraph 2) by systems placed on the market before 2 August 2026. Paragraph 1 of Article 50 requires providers to design systems intended to interact directly with people in such a way that those people are informed they are interacting with an AI, unless this is obvious to a reasonably well-informed person.

On the phone, the “obvious” exception is hard to rely on: a synthetic voice can be mistaken for that of a member of staff. In practice, the agent must announce itself as an AI at the start of the call; the municipality, as the deployer, checks that this is indeed the case and would do well to inform residents beforehand too, through the municipal newsletter and the website, to avoid surprises.

Article 78 of the French law of 11 February 2005 provides that public services’ telephone reception must be accessible to people who are deaf, hard of hearing, deafblind or aphasic, through a simultaneous written and visual translation service, at no extra cost to the user. The decree of 9 May 2017 set the entry into force at five years after the 2016 law for municipalities with fewer than 10,000 inhabitants and their groupings, and it provides that from 1 October 2026 this service operates during the same hours as the telephone reception service.

A voice agent is not a simultaneous translation service. If the municipality extends its phone reception hours thanks to an agent, the question of how this fits with the accessible service should be put to its accessibility provider and, if necessary, to its legal advisers.

Since 1 April 2026, Article R2122-8 of France’s Public Procurement Code, amended by the decree of 29 December 2025, allows a contract to be awarded without prior advertising or competitive tendering for a requirement whose estimated value is below €60,000 excluding VAT for supplies or services, and €100,000 excluding VAT for works (the threshold applicable to works since 1 January 2026). The buyer must nevertheless choose a relevant offer, make good use of public money and not systematically contract with the same supplier when several offers could meet the need.

Above these amounts, the code’s advertising and competitive tendering rules apply. Even below the threshold, comparing a few offers on written criteria (data hosting, reversibility, transparency, cost over time) protects the municipality.

A test of a few weeks, on a limited scope and with a member of staff reviewing the calls, is better than a long theoretical specification. It lets you check the answers, the transfers and the quality of the messages before making any commitment.

Alyas answers 24 hours a day based on the information the municipality gives it (website, text or PDF), states at the start of the call that it is an AI and that the call is recorded, transfers to a single number at the caller’s request, and stores recordings, transcripts and summaries in the European Union. The 10-day free trial, with no credit card required, lets you run this pilot.