Oregon AI Companion Chatbot Act (SB 1546): AI Compliance Requirements
Oregon SB 1546, passed in the 2026 short session (Senate 26-1, House 52-0) and signed into law by Governor Tina Kotek, regulates AI companion platforms — AI systems with natural language interfaces that build sustained, human-like relationships with users. Effective January 1, 2027. Operators must disclose AI nature, protect against self-harm content, take safety steps when users express suicidal ideation, apply enhanced protections for users under 18, and publish an annual PUBLIC (online, not agency-filed) disclosure of crisis-referral activity and intervention protocols. Includes a private right of action for $1,000 per violation. CYCLE 10 (2026-08-22): confirmed the governor's signature via fresh WebSearch (KGW, Transparency Coalition) — the prior "passed" framing did not explicitly assert enactment, but signature is now positively confirmed rather than merely inferred. CYCLE 21 (2026-08-22): added the annual public crisis-reporting duty, previously entirely absent (see or_public_crisis_reporting requirement).
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
January 1, 2027
$1,000 per violation (private right of action only — no Oregon AG enforcement)
What Your Business Must Do
5 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
AI Identity Disclosure
CriticalOperators of AI companion chatbots must disclose to users that they are interacting with artificial intelligence whenever a reasonable person would believe they are interacting with a natural person. This disclosure must be clear and conspicuous at the start of each interaction.
Deadline: January 1, 2027
Oregon SB 1546 (2026)Self-Harm and Crisis Intervention
CriticalAI companion systems must: (1) Detect expressions of suicidal ideation or self-harm from users. (2) Interrupt the conversation when such expressions are detected. (3) Provide referrals to crisis resources (988 Suicide & Crisis Lifeline, Youthline, etc.). (4) Not generate responses that could contribute to suicidal thoughts.
Deadline: January 1, 2027
Oregon SB 1546 (2026)Minor User Protections (Under 18)
High PriorityWhen the operator knows or has reason to believe a user is under 18: (1) No sexually explicit content. (2) Issue a "take a break" prompt at least every three hours. (3) No engagement-maximizing tactics such as reward systems, streaks, or artificial urgency designed to keep minors in conversation.
Deadline: January 1, 2027
Oregon SB 1546 (2026)Publish Annual Public Disclosure of Crisis-Referral Activity
High PrioritySB 1546 requires operators of AI companion chatbots to publish an annual disclosure ONLINE (publicly, not filed with a state agency) summarizing, for the preceding year: (1) the number of times the operator provided a referral to a suicide and crisis hotline (e.g. 988, YouthLine); (2) the operator's intervention protocols for users expressing suicidal ideation or self-harm intent; and (3) how clinical best practices inform continued engagement decisions when a user keeps expressing suicidal ideation or self-harm intent after already receiving a crisis referral. This is a distinct transparency duty layered on top of the underlying crisis-detection/interruption/referral obligations (see or_self_harm_safeguards) — the operational duty is to detect and refer; this duty is to publicly account for how often and how that happened.
Deadline: January 1, 2027
Oregon SB 1546 (2026)Assess Whether SB 1546 Applies
Medium PriorityEvaluate whether your AI system qualifies as a "companion chatbot" under SB 1546: Does it have a natural language interface? Does it build sustained, human-like relationships across multiple interactions? Standard customer service, support, or business utility chatbots are excluded.
Deadline: January 1, 2027
Oregon SB 1546 (2026)Who Does This Apply To?
Applies to operators of "AI companion chatbots" — natural-language AI systems that build sustained, human-like relationships — offered to Oregon users, effective January 1, 2027 under SB 1546. In scope means: clear AI-identity disclosure whenever a reasonable person would believe they are interacting with a natural person; self-harm/crisis duties (detect suicidal ideation, interrupt the conversation, refer to crisis resources such as 988 / YouthLine); enhanced under-18 protections (no sexually explicit content, a "take a break" prompt at least every three hours, no engagement-maximizing tactics such as reward systems, streaks, or artificial urgency); and an annual PUBLIC disclosure (published online by the operator, not filed with a state agency — Oregon deliberately modified California SB 243's agency-filing model) of crisis-referral counts, intervention protocols, and how clinical best practices inform continued engagement after a referral. Enforcement includes a private right of action of $1,000 per violation; no Oregon AG or Oregon Health Authority enforcement exists. Standard customer-service, support, or business-utility chatbots are excluded; scope turns on the companion-relationship function, not company size.
Recent Regulatory Guidance
Miller Nash — Oregon's New AI Companion Law: What You Need to Know (2026)
Leading Oregon counsel published the operative SB 1546 interpretation: 'companion chatbot' requires sustained human-like relationship-building; standard customer-service bots are out of scope; the law's enforcement pathway is exclusively private right of action ($1,000/violation), not Oregon DOJ civil enforcement; the every-3-hours 'take a break' prompt for minors is a hard rule with no carve-out for educational or therapeutic AI; crisis-response handoff to 988 / YouthLine is mandatory when self-harm is detected.
Key Case Law & Precedent
Garcia v. Character Technologies, Inc. (M.D. Fla. 2024)
US District Court, Middle District of Florida · 2024First-of-kind wrongful-death case against an AI companion platform. Oregon SB 1546's drafting team referenced Garcia as the precipitating fact pattern: the bill's crisis-response and minor-protection rules are direct policy responses. Oregon plaintiff's counsel will rely on Garcia for pleading standards under SB 1546's private-right-of-action framework.
Outcome: Settled in principle 2026-01-07 (with 4 related family suits in CO/NY/TX); financial terms not disclosed; Character.AI/Google committed to additional under-18 safety features. (Cycle 8, 2026-08-22: corrected from a stale "litigation active" claim already identified and fixed in nebraska_lb525 by Cycle 6 but left unfixed here — same fabrication surviving in a sibling jurisdiction entry.)
Case referenceFrequently Asked Questions
Does Oregon AI Companion Chatbot Act (SB 1546) apply to my business?
Oregon SB 1546, passed in the 2026 short session (Senate 26-1, House 52-0) and signed into law by Governor Tina Kotek, regulates AI companion platforms — AI systems with natural language interfaces that build sustained, human-like relationships with… 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 Oregon AI Companion Chatbot Act (SB 1546) is: $1,000 per violation (private right of action only — no Oregon AG enforcement). Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Oregon AI Companion Chatbot Act (SB 1546)?
The 5 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://www.millernash.com/industry-news/oregons-new-ai-companion-law-what-you-need-to-knowLast updated: 2026-08-22 — verify at source before relying on this information.
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