Troubleshooting: Control 2.19 — Customer AI Disclosure and Transparency

Last Updated: April 2026

Common Issues at a Glance

Issue	Likely Cause	First Action
Disclosure not appearing on first turn	Conversation Start topic missing or disclosure node not first	Open the Conversation Start topic; ensure the disclosure Send-message node is the first node
Disclosure appears in Web but not in Teams	Custom welcome message is overriding the Conversation Start topic in the Teams channel	Disable the channel-level welcome message and let the topic fire
`Transfer conversation` node greyed out	Engagement hub not configured at the agent level	Configure handoff in Settings → Customer engagement (Dynamics 365 / generic hub) before adding the node
Handoff fires but no live agent receives	Queue routing rules / unified-routing workstream not bound	Verify the workstream + queue exist and that the bot user is added to the queue
Periodic reminder never fires	Threshold variable not initialised; condition uses wrong namespace	Set `System.Conversation.LastReminderTime` on Conversation Start; re-check condition expression
Disclosure event not logged	`LogAiDisclosureEvent` flow disabled or connection broken	Power Automate → check flow run history; reauthorize the Dataverse connection
Wrong disclosure level surfaces	Agent's zone classification incorrect in Agent Card	Reconcile with Control 3.1 inventory and reapply the right copy version
Jurisdiction overlay missing	Jurisdiction signal not flowing into the agent	Verify the upstream variable (e.g., session token claim or CRM lookup) is populated before the disclosure node

Symptoms: Users can interact without seeing AI disclosure.

Diagnostic steps:

Confirm the disclosure lives in the Conversation Start topic (not the legacy Greeting topic) and is the first node
In Copilot Studio, open the Test bot pane and start a new conversation — does the disclosure appear here?
Reproduce in each customer channel (Web Chat, Teams, Omnichannel, Direct Line)
For Teams: open Teams Admin Center → Manage apps → your agent → confirm no custom welcome message is set on the Teams channel that would suppress the topic
For Direct Line / custom client: ensure the client sends an event activity of type conversationUpdate to fire the Conversation Start topic

Resolution:

Move the disclosure Send-message node to position 1 in the Conversation Start topic
Remove any condition node before it that might short-circuit it
Republish the agent and clear channel caches
For custom Direct Line clients, verify the welcome event handshake

Symptoms: User asks for a human; the bot keeps responding as AI.

Diagnostic steps:

Open system topic Escalate → confirm trigger phrases include common synonyms (human, person, representative, advisor, agent, complaint)
Confirm a Transfer conversation node exists at the end of the topic (not just a Send-message that says "transferring…")
In the node properties, confirm the engagement hub dropdown is set (not "None") and the queue/workstream is selected
For Dynamics 365 Customer Service: confirm the bot's application user is added as a queue member and the unified-routing workstream is published
Check the most recent topic-execution trace in Copilot Studio for the Escalate topic

Resolution:

Add missing trigger phrases (re-train the topic if necessary)
Configure the engagement hub at the agent level (Settings → Customer engagement)
Add the bot user to the target queue
See Microsoft Learn: hand off to a live agent and Configure handoff to Dynamics 365 Customer Service

Symptoms: Compliance cannot find disclosure rows in fsi_aidisclosurelog.

Diagnostic steps:

In Power Automate, open the LogAiDisclosureEvent flow → 28-day run history → look for failed runs
If runs fail with auth errors, the Dataverse connection has expired or the connection owner left the org
If runs succeed but no row appears, check Create record action input — column names may have drifted (fsi_eventtype vs fsi_event_type, etc.)
Confirm the flow is invoked from each disclosure-related node in the topic

Resolution:

Reauthorize the Dataverse connection under a service account / managed identity
Re-bind action inputs to the correct logical column names
Add the flow call to any topic node that surfaces disclosure but currently skips logging

Symptoms: Long sessions never see a reminder.

Diagnostic steps:

Open the AI Reminder topic → check the trigger condition syntax against current Power Fx grammar
Confirm System.Conversation.LastReminderTime is initialised on Conversation Start (otherwise the now() - blank comparison fails silently)
Check whether the reminder is competing with a higher-priority topic that always fires first

Resolution:

Initialise the variable in Conversation Start
Adjust topic priority so the reminder is reachable
Lower the threshold in non-prod to validate the path before restoring production threshold

Symptoms: A Zone 3 agent shows the basic disclosure, or vice versa.

Diagnostic steps:

Open the Agent Card (Control 3.1) and confirm the recorded zone classification
Open the Conversation Start topic and confirm the message variant matches the zone
Inspect the disclosure-version global variable for staleness

Resolution:

Update the Agent Card and re-publish the matching disclosure variant
If the zone genuinely changed, run the Control 2.3 zone-promotion review before changing copy

Use a trigger phrase
Confirm the live agent (or your test queue) receives the conversation with full context
Confirm EscalationOffered and EscalationAccepted rows in the log

Tier	Owner	When to Engage
1	Copilot Studio Agent Author	Topic content, node configuration, copy fixes
2	Power Platform Admin	Environment, connectors, engagement-hub binding, DLP impact
3	AI Administrator	Tenant-level Copilot settings affecting disclosure surfaces
4	Compliance Officer	Disclosure copy approval, regulatory interpretation
5	Legal Counsel	State-law (CA/UT/CO) edge cases, UDAAP exposure
6	Microsoft Support	Platform behavior (handoff failures, channel regressions) — open ticket via Power Platform Admin Center

Limitation	Impact	Workaround
No native, tenant-wide "AI disclosure" toggle in Copilot Studio	Each agent must implement disclosure individually	Use a shared solution / template agent and clone for new agents
Topic content is not exposed by an admin API	Disclosure copy cannot be mutated via PowerShell	Use Copilot Studio portal or solution import; gate via Control 2.4 ALM
Some custom Direct Line clients suppress the conversation-start event	Disclosure may not render	Implement a client-side disclosure render OR require a starter intent that fires the topic
Forced acknowledgement of disclosure is not a built-in capability	Cannot block conversation until user clicks `[I understand]` natively	Use an Adaptive Card with required input + Question node that loops until acknowledged
Generic engagement-hub adapters require custom development	Non-Microsoft hubs need an adapter	Follow Configure handoff to a generic engagement hub and the contact-center skill-handoff sample