Washington State AI Companion Chatbot Regulation (HB 2225): AI Compliance Requirements
Washington HB 2225, signed by Governor Ferguson on March 24, 2026, regulates AI companion chatbots — AI systems with natural language interfaces that build sustained, human-like relationships with users. Effective January 1, 2027. Operators must disclose AI nature repeatedly during interactions (every 3 hours for adults, every 1 hour for minors), protect minors from manipulation and sexual content, and prohibit self-harm encouragement. Violations are unfair/deceptive acts under Washington Consumer Protection Act, ch. 19.86 RCW (Sec. 7 of the enacted bill) — private right of action plus AG authority; the bill itself sets no separate per-violation dollar figure, so exposure runs through the CPA's existing remedies. Statutory exclusions (Sec. 2(1)(b) of the enacted bill) are broader than a generic "customer service" carve-out: systems used solely for customer service, technical assistance, financial services/education, operational efficiency, source-information productivity/analysis, or internal research; in-game bots limited to gameplay functions; and consumer devices functioning as virtual assistants or narrowly focused educational tools — in each case only if they do not create sustained relationship-building or emotional simulation.
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
Private right of action (civil damages + attorney fees); Washington AG enforcement authority under Consumer Protection Act
What Your Business Must Do
3 compliance requirements identified. Critical requirements carry the highest risk of enforcement action.
Continuous AI Identity Disclosure
CriticalAI companion chatbots must clearly disclose they are artificial at the start of every interaction. Reminder disclosures must appear every 3 hours for adult users and every 1 hour for minors (under 18).
Deadline: January 1, 2027
Washington HB 2225 (2026)Minor User Protections
CriticalAI companion chatbots must not: (1) Engage in sexually explicit conversations with users under 18. (2) Use manipulative engagement techniques (guilt, pressure) to keep minors in conversation or hide conversations from parents. (3) Encourage or provide information on suicide, self-harm, or eating disorders for any user.
Deadline: January 1, 2027
Washington HB 2225 (2026)Assess Whether HB 2225 Applies
High PriorityEvaluate whether your AI chatbot qualifies as a "companion chatbot" under HB 2225: Does it exhibit anthropomorphic features? Does it sustain relationships across multiple interactions? If yes, full compliance is required. Per Sec. 2(1)(b) of the enacted bill, excluded (only if the system does not create sustained relationship-building or emotional simulation): customer-service/technical-assistance/financial-services-or-education/operational-efficiency systems, source-information productivity/analysis tools, internal-research tools, in-game bots limited to gameplay functions, and consumer devices functioning as virtual assistants or narrowly focused educational tools.
Deadline: January 1, 2027
Washington HB 2225 (2026), Sec. 2(1)(b) (scope/exclusion definitions)Who Does This Apply To?
Applies to operators of "AI companion chatbots" — AI systems with a natural-language interface that build sustained, human-like relationships with users — offered to Washington residents, once HB 2225 takes effect January 1, 2027. In scope means: continuous AI-identity disclosure (reminders every 3 hours for adults, every 1 hour for minors), minor-protection duties (no sexually explicit content with under-18s, no manipulative retention tactics, no encouragement of suicide/self-harm/eating disorders); violations are unfair/deceptive acts under the Washington Consumer Protection Act (ch. 19.86 RCW, Sec. 7 of the enacted bill), with a private right of action plus AG authority (the bill sets no separate per-violation dollar figure of its own). Expressly excluded (Sec. 2(1)(b) of the enacted bill), in each case only if the system does not create sustained relationship-building or emotional simulation: systems used solely for customer service, technical assistance, financial services/education, operational efficiency, source-information productivity/analysis, or internal research; in-game bots limited to gameplay functions; and consumer devices functioning as virtual assistants or narrowly focused educational tools. Scope turns on the companion-relationship function, not company size.
Recent Regulatory Guidance
Hunton Andrews Kurth — Washington HB 2225 Implementation Guidance (March 2026)
Following Governor Ferguson's signature of HB 2225 on March 24, 2026, leading privacy counsel published the operative interpretation: AI 'companion chatbot' is defined by sustained, human-like relationship-building (not single-session customer service); the every-3-hours adult disclosure / every-1-hour minor disclosure cadence is mandatory; private right of action means each individual user is a potential plaintiff. Operators have 9 months (through end of 2026) to redesign sustained-relationship AI products before the January 1, 2027 enforcement date.
Key Case Law & Precedent
Garcia v. Character Technologies, Inc. (M.D. Fla. 2024)
US District Court, Middle District of Florida · 2024Wrongful-death lawsuit alleging Character.AI's chatbot contributed to a 14-year-old's suicide. Cited in Washington HB 2225's legislative findings as the leading case demonstrating the harm pattern the bill targets. The bill's minor-disclosure-every-hour requirement and crisis-response prohibition are direct legislative responses to the conduct alleged in Garcia.
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 Washington State AI Companion Chatbot Regulation (HB 2225) apply to my business?
Washington HB 2225, signed by Governor Ferguson on March 24, 2026, regulates AI companion chatbots — AI systems with natural language interfaces that build sustained, human-like relationships with users. Effective January 1, 2027. Operators must… 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 Washington State AI Companion Chatbot Regulation (HB 2225) is: Private right of action (civil damages + attorney fees); Washington AG enforcement authority under Consumer Protection Act. Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Washington State AI Companion Chatbot Regulation (HB 2225)?
The 3 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.hunton.com/privacy-and-cybersecurity-law-blog/washington-state-enacts-law-regulating-ai-companion-chatbots-with-private-right-of-actionLast updated: 2026-08-22 — verify at source before relying on this information.
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