Source: JD Supra

Oregon and Washington enacted companion chatbot laws in March 2026 that will take effect on January 1, 2027, following California’s earlier statute. Washington’s HB 2225 defines “AI companion chatbot” around natural language systems that provide adaptive, human-like responses and can sustain relationships across interactions, while excluding certain business bots, video-game-limited chatbots, and stand-alone virtual assistants that do not elicit emotional responses. Operators under Washington must disclose at the start of interactions and at least every three hours (every hour for known minors or bots directed to minors), implement measures preventing chatbots from claiming to be human, publish their suicide/self-harm response protocols, and face enforcement under Washington’s Consumer Protection Act with a private right of action for injunctive relief, actual damages, and attorney’s fees.

Oregon’s SB 1546 regulates “artificial intelligence companions” using behavioral criteria such as retaining prior interactions, asking unsolicited emotional questions, and sustaining personal dialogs, and it excludes a range of customer service, education, research, and limited video-game features. Oregon requires operators to notify users that outputs are artificially generated when a reasonable person would otherwise believe they are interacting with a natural person, to maintain evidence-based protocols to detect suicidal ideation and prevent content encouraging self-harm, to provide 9-8-8 crisis referrals (or a youthline for users under 25), and to publish details and annual reports on crisis referrals without personal data. Both states provide private rights of action (Oregon’s remedies include the greater of actual damages or $1,000 per violation), impose specific protections for minors and limits on manipulative engagement techniques, and contain several points of divergence from California’s model that operators should evaluate.