Skip to content
هذه ترجمة للتسهيل فقط. النسخة الإنجليزية هي النسخة الرسمية والملزمة قانونيا. عرض النسخة الإنجليزية
US-AKFEDERAL profile

Alaska — Federal AI Compliance Profile + State AI-CSAM/Deepfake Law (HB 239 omnibus crime bill, became law 2026-06-18) + Tribal Sovereignty: AI Compliance Requirements

Alaska enacted its first AI-specific criminal provisions in 2026: HB 47's AI-generated child-sexual-abuse-material and deepfake-harassment provisions were folded into the omnibus crime bill HB 239, which passed the Alaska Legislature 2026-05-20 (Senate unanimous 20-0; House 39-1) and became law 2026-06-18 as Chapter 9, SLA 2026 — WITHOUT the Governor's signature (Dunleavy allowed it to become law without formally signing it; a gov.alaska.gov press release titled "Governor...Signs..." notwithstanding, Alaska Public Media's direct reporting confirms no formal signature). HB 239 creates state felony charges for AI-generated CSAM and a new misdemeanor for distributing a "forged digital likeness" (deepfake) "with intent to defraud, harass, threaten, or intimidate" (with an exception for satire). Separately, SB 2 (election-deepfake/state-agency-AI) died in committee, SB 64 was vetoed, and HCR 3 created only a study task force — none of those became law. Note: Cori Mills became Acting Attorney General May 14, 2026 after the Legislature rejected the Governor's AG appointee. Federal laws remain the primary compliance framework beyond HB 239's narrow criminal scope. Alaska presents unique considerations: (1) Tribal sovereignty — AI systems processing data of Alaska Native communities may implicate tribal data sovereignty rights; federal Indian law (ICRA, tribal consultation requirements) applies. (2) Critical infrastructure AI — oil/gas operations (North Slope, Trans-Alaska Pipeline), fishing, and mining operations use AI in safety-critical contexts governed by PHMSA, OSHA, and EPA digital safety guidelines. (3) Telehealth AI — remote healthcare in rural communities is regulated by CMS, DEA telemedicine AI rules, and FDA SaMD guidance. Monitor legis.alaska.gov for new AI legislation. (Verify-the-negative: Alaska still has NO comprehensive/horizontal private-sector AI statute, and NO enacted election-deepfake or state-agency-AI law.)

Check your compliance — freeDownload checklist

Summary of publicly-available regulatory text as of 2026-08-22. Verify against current official sources before relying on this for compliance decisions. Not legal advice.

Key Facts

Effective Date

January 1, 2024

Maximum Penalty

HB 239 (became law 2026-06-18, Chapter 9 SLA 2026, without the Governor's signature): state felony charges for AI-generated child sexual abuse material; misdemeanor for distributing a "forged digital likeness" with intent to defraud, harass, threaten, or intimidate (exact felony/misdemeanor classification not independently re-derived from primary bill text this cycle — confirm against the enacted Session Laws of Alaska text). Federal: FTC civil penalties up to $51,744/violation; EEOC Title VII damages up to $300K; FCRA statutory damages $100–$1,000/violation.

What Your Business Must Do

6 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.

Alaska HB 239 (2026) — AI-Generated CSAM Felony + Deepfake-Harassment Misdemeanor

High Priority

Alaska's omnibus crime bill HB 239 (passed 2026-05-20, became law 2026-06-18 as Chapter 9 SLA 2026 without Gov. Dunleavy's signature) folded in HB 47's AI provisions: state felony charges for AI-generated child sexual abuse material, and a new misdemeanor for distributing a "forged digital likeness" (AI deepfake) with intent to defraud, harass, threaten, or intimidate (satire exception applies). Counsel should confirm the exact codified statute sections, felony/misdemeanor classes, and effective date against the enacted Session Laws of Alaska text — not independently re-derived from primary source this cycle. legal_review_pending.

Deadline: June 18, 2026

HB 239 (2026), Chapter 9, SLA 2026 (incorporating HB 47/SB 247's AI provisions) — exact AS section not independently confirmed this cycle

FTC Act § 5 — Unfair or Deceptive AI Practices

High Priority

FTC Act § 5 applies to all commercial AI deployed in Alaska. Prohibited: AI that makes false claims, uses dark patterns, or delivers biased outputs without disclosure. Alaska's fishing industry and oil/gas operators using AI must ensure AI safety and performance claims are truthful. Cite: FTC Policy Statement on AI (2022); FTC Algorithmic Discrimination guidance (2022).

15 U.S.C. § 45(a) (unfair/deceptive practices); civil-penalty authority § 45(l), § 45(m)(1)(A); Alaska Consumer Protection Act (AS 45.50.471)

EEOC / Title VII / ADA — AI Employment Discrimination

High Priority

AI hiring, scheduling, and performance management tools used by Alaska employers must comply with Title VII, ADA, ADEA, and GINA. Particular concern: AI scheduling algorithms in fishing and resource industries that may inadvertently discriminate against Alaska Native workers on protected characteristics. Test AI employment tools for disparate impact before deployment. Cite: EEOC v. iTutorGroup (2022); EEOC AI and ADA Technical Assistance (2022).

Title VII, 42 U.S.C. § 2000e-2; ADA, 42 U.S.C. § 12112; ADEA, 29 U.S.C. § 623; damages caps at 42 U.S.C. § 1981a(b)(3)

Alaska Native Tribal Data — Federal Indian Law Considerations

Medium Priority

AI systems processing data of Alaska Native community members or operating on tribal lands should consider: (1) Tribal consultation requirements under E.O. 13175. (2) Tribal sovereignty over data collected within tribal jurisdictions. (3) FERPA/COPPA for Alaska Native K-12 students. (4) HIPAA for Indian Health Service and tribal health program data. Consult with tribal governments before deploying AI systems affecting Alaska Native communities.

FCRA — AI Adverse Action Notices

Medium Priority

AI-based credit, lending, or insurance decisions adverse to Alaska consumers must provide specific reasons under FCRA. "Model score" or "algorithm output" is insufficient — see CFPB Circular 2022-03. Implement specific adverse action reason codes for AI-driven decisions.

15 U.S.C. § 1681b(b)(3) (adverse action notice); §§ 1681n, 1681o (civil liability); CFPB Circular 2022-03

Monitor Alaska AI Legislation

Lower Priority

Monitor legis.alaska.gov. Alaska Legislature meets annually January-May. Alaska AG (law.alaska.gov) may apply Alaska Consumer Protection Act (AS 45.50.471) to deceptive AI practices.

Recent Regulatory Guidance

guidance2022-04

FTC — Luring Test: Understanding Algorithmic Harm in AI Systems (2022)

FTC guidance on algorithmic harm: AI systems that cause foreseeable harm to consumers or that produce outputs the average reasonable consumer would find deceptive are subject to FTC Act § 5 enforcement. Algorithmic systems must be transparent about their limitations; AI recommendations must be distinguishable from paid/sponsored content; AI systems used in consequential consumer decisions (loans, housing, employment, healthcare) face heightened FTC scrutiny. Applicable to all Alaska commercial AI deployments.

Frequently Asked Questions

Does Alaska — Federal AI Compliance Profile + State AI-CSAM/Deepfake Law (HB 239 omnibus crime bill, became law 2026-06-18) + Tribal Sovereignty apply to my business?

Alaska enacted its first AI-specific criminal provisions in 2026: HB 47's AI-generated child-sexual-abuse-material and deepfake-harassment provisions were folded into the omnibus crime bill HB 239, which passed the Alaska Legislature 2026-05-20… Use Aegis Firma's free scanner to get a personalized assessment in under 5 minutes.

What is the penalty for non-compliance?

The maximum penalty under Alaska — Federal AI Compliance Profile + State AI-CSAM/Deepfake Law (HB 239 omnibus crime bill, became law 2026-06-18) + Tribal Sovereignty is: HB 239 (became law 2026-06-18, Chapter 9 SLA 2026, without the Governor's signature): state felony charges for AI-generated child sexual abuse material; misdemeanor for distributing a "forged digital likeness" with intent to defraud, harass, threaten, or intimidate (exact felony/misdemeanor classification not independently re-derived from primary bill text this cycle — confirm against the enacted Session Laws of Alaska text). Federal: FTC civil penalties up to $51,744/violation; EEOC Title VII damages up to $300K; FCRA statutory damages $100–$1,000/violation.. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.

How do I comply with Alaska — Federal AI Compliance Profile + State AI-CSAM/Deepfake Law (HB 239 omnibus crime bill, became law 2026-06-18) + Tribal Sovereignty?

The 6 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. Aegis Firma generates all required documents automatically.

Official Source

https://alaskapublic.org/news/politics/alaska-legislature/2026-06-26/dozens-of-alaska-bills-meet-their-fate-at-gov-dunleavys-desk

Last updated: 2026-08-22 — verify at source before relying on this information.

Don't leave compliance to chance

Aegis Firma scans your AI tools, tells you exactly which regulations apply, and generates all required documents — in 30 minutes.

Start your free compliance scan