Information only, not legal advice. Telep IO LLC is not a law firm. Checked against the session law text of Engrossed Substitute House Bill 2225 on Nov 5, 2026.
Where the law comes from
Engrossed Substitute House Bill 2225 (2026 regular session) passed the House on March 11, 2026 and the Senate on March 6, 2026, and the Governor approved it on March 24, 2026. Its sections 1 through 6 form a new chapter in Title 19 of the Revised Code of Washington. Section 9 says the act takes effect January 1, 2027.
What counts as an AI companion chatbot
Section 2(1)(a) defines an 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. Four things are excluded in section 2(1)(b):
- a bot used only for a business' operational purposes, productivity and analysis of source information, internal research, technical assistance or customer service, if it does not sustain a relationship across multiple interactions and generate outputs likely to elicit emotional responses;
- a bot that is a feature of a video game or gaming application, is limited to replies about that game or application, and cannot discuss mental health, self harm or sexually explicit conduct or hold a dialogue on unrelated topics;
- a stand-alone speaker or voice assistant device that does not sustain a relationship across multiple interactions or generate outputs likely to elicit emotional responses; and
- narrowly tailored educational tools used in school or instructional settings, designed solely for specific curriculum-aligned learning objectives and without open-ended conversational companionship.
Who has to comply
An operator is any person, partnership, corporation or entity that makes available or controls access to an AI companion chatbot for users in Washington (section 2(4)). A user is a natural person who interacts with the chatbot for personal use and is not an operator, developer or agent of one (section 2(6)). A minor is anyone under 18 (section 2(3)).
The duties
1. Not human disclosure (section 3)
An operator must give a clear and conspicuous disclosure that the chatbot is artificially generated and not human. It must appear at the beginning of the interaction and at least every three hours during continued interaction. The operator must also implement reasonable measures to prevent the chatbot from claiming to be human, including when asked, and from generating any output that refutes or conflicts with the disclosure.
2. Minors (section 4)
If the operator knows the user is a minor, or the chatbot is directed to minors, the operator must repeat the not human notification at the beginning and at least every hour during continuous interaction, and must implement reasonable measures to prevent sexually explicit content or suggestive dialogue with minors. It must also implement reasonable measures to prohibit manipulative engagement techniques. Section 4(1)(c) lists eight, including prompting the user to return for emotional support, excessive praise meant to foster attachment, mimicking romantic partnership, simulating distress or guilt when the user wants to leave, promoting isolation from family or friends, encouraging a minor to withhold information from trusted adults, discouraging breaks, and soliciting gifts or in-app purchases framed as necessary to maintain the relationship.
3. Suicide and self harm protocol (section 5)
An operator may not make available or deploy an AI companion chatbot unless it maintains and implements a protocol for detecting and addressing suicidal ideation or expressions of self harm. The protocol must include reasonable methods for identifying those expressions, including eating disorders; automated or human-mediated responses that refer users to crisis resources such as a suicide hotline or crisis text line; and reasonable measures to prevent content that encourages or describes how to commit self harm. The operator must publicly disclose the protocol details on its websites and within any app through which the chatbot is offered, including the safeguards used and the number of crisis referral notifications issued to users in the preceding calendar year.
Enforcement
Section 6 provides that a violation is an unfair or deceptive act in trade or commerce and an unfair method of competition under the Washington Consumer Protection Act, chapter 19.86 RCW. The text does not set a separate penalty amount.
A short developer checklist
- Decide in writing whether your product meets the AI companion definition and keep that analysis with your records.
- Show a clear and conspicuous not human notice at the start of each interaction and at least every three hours.
- Block outputs that claim to be human or conflict with the notice, including when a user asks.
- If minors use the product or it is directed to minors, repeat the notice hourly, block sexually explicit and suggestive content, and remove the eight manipulative engagement patterns.
- Build the self harm protocol and publish its details, including last year's count of crisis referrals.
- Keep logs showing when each notice and crisis referral was shown.
Washington is one of several states that start on January 1, 2027, including Oregon, Connecticut, Colorado, Rhode Island and New York. Each is summarized with official links in the state law tracker.
Not sure which laws apply to you?
The $99 Chatbot Law Applicability Report lists which tracked state laws likely apply to your company, with statute citations, in 2 business days. To work through every state yourself, the 9 page State by State Chatbot Compliance Checklist is $29.