Compliance Stuff

Continuing the trend of new state-by-state artificial intelligence (“AI”) regulations, Oregon and Washington both enacted laws regulating AI companion chatbots in March 2026, following California’s lead . Oregon’s SB 1546 and Washington’s HB 2225 will both take effect on January 1, 2027. This Legal Update provides an overview of these new laws and summarizes the key differences from California’s companion chatbot law. I. WASHINGTON HB 2225 Similar to California’s companion chatbot law, Washington’s HB 2225 defines “AI companion chatbot” as an “artificial intelligence system with a natural language interface that provides adaptive, human-like responses to user inputs, including by exhibiting anthropomorphic features, and is able to sustain a relationship across multiple interactions.” HB 2225 broadly excludes: chatbots for business functions (such as technical assistance and customer service) “if such bot does not sustain a relationship across multiple interactions and generate outpu...

New York became the first state to regulate emotionally responsive “AI companion” chatbots on November 5, 2025, when the Artificial Intelligence Companion Models Law entered effect . California’s SB 243 follows close behind, entering effect in January 2026. Both laws respond to growing concern over the potential mental health and safety risks associated with emotionally responsive AI systems, particularly when used by minors. The bills target similar concerns over these technologies but require different compliance measures, including related to notices, reports, and disclosures. Notably, California’s SB 243 authorizes a private right of action whereas New York’s law only authorizes the Attorney General to seek civil penalties. New York’s Artificial Intelligence Companion Models Law (General Business Law Article 47) Overview Codified under  General Business Law Article 47 , the AI Companion Models Law establishes mandatory safety protocols for companies operating AI companion model...