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New York AI Companion Models Law (A6767, codified GBL Article 47): AI Compliance Requirements

New York Governor Kathy Hochul signed Assembly Bill A6767 (introduced 2025-03-13) creating the Artificial Intelligence Companion Models Law, codified as General Business Law Article 47 (§§1700-1704), which took effect November 5, 2025. The law requires operators of AI companion models — AI systems designed to simulate sustained human-like companionship or emotional relationships — to clearly disclose their AI nature to users. Disclosures must be made verbally or in writing, and must include a daily notification or every-3-hour reminder for continuous interactions. Operators must implement protocols to detect and respond to suicidal ideation or self-harm expressed by users, including connecting users with mental health services. The law targets companionship AI (not general business chatbots) and is enforced by the New York AG, with civil penalties up to $15,000 per day per violation (§1703), collected penalties funding suicide-prevention programs.

Summary of publicly-available regulatory text as of 2026-08-25. Verify against current official sources before relying on this for compliance decisions. Not legal advice.

Key Facts

Effective Date

November 5, 2025

Maximum Penalty

New York AG enforcement; civil penalties up to $15,000 per day per violation (GBL §1703), directed to a suicide-prevention fund

What Your Business Must Do

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

AI Companion Identity Disclosure

Critical

Section 1702 requires an operator to "provide a clear and conspicuous notification to a user at the beginning of any AI companion interaction" stating that the user is not communicating with a human. The notification may be delivered orally or in writing. For a continuing interaction the statute sets both a ceiling and a floor on repetition: the notification "need not exceed once per day and at least every three hours for continuing AI companion interactions" — so a session running past three hours needs a further notice, while a heavily-used day cannot be forced past one notice per day. Build the notice into session start rather than onboarding: it is owed at the beginning of ANY interaction, not once per account. Already in effect as of November 5, 2025.

Deadline: November 5, 2025

GBL Art. 47, § 1702 (Notifications) — corrected R503 from § 1701, which is the crisis-protocol section

Self-Harm Detection and Crisis Response

Critical

Section 1701 is framed as a PROHIBITION, not a best practice: "It shall be unlawful for any operator to operate for or provide an AI companion to a user unless such AI companion contains a protocol to take reasonable efforts for detecting and addressing suicidal ideation or expressions of self-harm expressed by a user to the AI companion." Operating without the protocol is itself the violation — no user has to be harmed. The protocol must include, at minimum, detection of user expressions of suicidal ideation or self-harm, and, upon detection, a notification to the user referring them to crisis service providers "such as the 9-8-8 suicide prevention and behavioral health crisis hotline under section 36.03 of the mental hygiene law, a crisis text line, or other appropriate crisis services". Name the specific referral targets in your protocol rather than describing them generically, document the detection method, and keep evidence that the protocol was in the product before it was offered to New York users.

Deadline: November 5, 2025

GBL Art. 47, § 1701 (Prohibitions and requirements) — corrected R503 from § 1702, which is the notification section

Who Does This Apply To?

Applies — already in effect since November 5, 2025 — to operators of an "AI companion" as defined by General Business Law § 1700 (Article 47, enacted by A 6767; the entry's prior reference to "Assembly Bill A3008" was a stale draft-bill number and was removed in R503). An AI companion is a system using artificial intelligence, generative artificial intelligence and/or emotional recognition algorithms designed to simulate a sustained human or human-like relationship with a user — the statutory indicia being retention of prior interaction data, asking unprompted emotion-based questions, and sustaining ongoing personal dialogue. Section 1700 expressly excludes three things, and those exclusions are where most business chatbots land: customer-service systems providing commercial information, systems primarily designed for efficiency, research or technical assistance, and internal employee productivity systems. "Operator" is broad — any person, partnership, association, firm or business entity, or any member, affiliate, subsidiary or beneficial owner, that operates or provides an AI companion — so a parent or beneficial owner can be reached alongside the operating entity. A "user" must be using the companion for PERSONAL use within the state and must not be the operator or its agent or affiliate, which keeps internal staff deployments outside the article. In scope means two duties: § 1702, a clear and conspicuous notification, orally or in writing, at the beginning of any AI companion interaction that the user is not communicating with a human, repeated for continuing interactions on the statute's formula (need not exceed once per day, and at least every three hours); and § 1701, a protocol taking reasonable efforts to detect and address suicidal ideation or expressions of self-harm, which on detection notifies the user with a referral to crisis service providers such as the 9-8-8 hotline under Mental Hygiene Law § 36.03, a crisis text line, or other appropriate crisis services. Section 1701 is a prohibition on operating or providing the companion at all without that protocol, so the duty attaches at launch. Enforced by the New York Attorney General under § 1703, with civil penalties up to $15,000 per day for a violation of § 1701 or § 1702, and all fees, fines and penalties deposited into the suicide prevention fund established by State Finance Law § 99-ss. There is no company-size threshold: the trigger is the companionship / emotional-relationship purpose.

Recent Regulatory Guidance

guidance2025-11

New York — AI Companion Safeguard Law (General Business Law Article 47), effective Nov 5, 2025

New York's AI Companion Models law (General Business Law Article 47, §§1700–1704; enacted via A6767), effective November 5, 2025, requires operators of AI companions to notify users at the start of each interaction and at least every three hours that they are interacting with a computer program and not a human being, and to maintain a protocol that refers users expressing suicidal ideation or self-harm to crisis service providers. The New York Attorney General enforces the law (civil penalties up to $15,000 per day under §1703), with collected penalties directed to a suicide-prevention fund.

Key Case Law & Precedent

Garcia v. Character Technologies, Inc. (M.D. Fla. 2024)

US District Court, Middle District of Florida · 2024

Wrongful-death lawsuit filed by Megan Garcia alleging Character.AI's chatbot contributed to her 14-year-old son's suicide. The first major wrongful-death case against an AI companion platform. NY AG cites Garcia in explaining why minor-protection requirements for companion AI are not optional and why the duty to warn / refuse / refer applies at the platform level.

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 reference

Frequently Asked Questions

Does New York AI Companion Models Law (A6767, codified GBL Article 47) apply to my business?

New York Governor Kathy Hochul signed Assembly Bill A6767 (introduced 2025-03-13) creating the Artificial Intelligence Companion Models Law, codified as General Business Law Article 47 (§§1700-1704), which took effect November 5, 2025. The law… 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 New York AI Companion Models Law (A6767, codified GBL Article 47) is: New York AG enforcement; civil penalties up to $15,000 per day per violation (GBL §1703), directed to a suicide-prevention fund. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.

How do I comply with New York AI Companion Models Law (A6767, codified GBL Article 47)?

The 2 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.nysenate.gov/legislation/laws/GBS/A47

Last updated: 2026-08-25 — verify at source before relying on this information.

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