Minnesota — Federal AI Profile + State AI Laws (§609.771 election deepfakes; §§604.32/617.262 NCII; §325E.91 nudification ban, live since Aug 2026): AI Compliance Requirements

Minnesota has multiple in-force AI-specific laws binding private actors. (1) Minn. Stat. § 609.771 criminalizes knowingly disseminating an AI deepfake, without consent, with intent to injure a candidate or influence an election within defined pre-election windows (enacted 2023; amended 2024 effective July 1, 2024) — misdemeanor base, gross misdemeanor if intended to cause violence/bodily harm, felony (up to 5 years/$10,000) on a repeat within 5 years; it remains in force despite the Kohls v. Ellison First Amendment challenge (Eighth Circuit affirmed denial of a preliminary injunction 2026-02-09 on the merits, no injunction in place); a related case, X Corp. v. Ellison, proceeds separately on a Section 230 claim while its constitutional claims are stayed pending the Kohls appeal. (2) Minn. Stat. §§ 604.32 (civil) and 617.262 (criminal) prohibit nonconsensual dissemination of AI sexual deepfakes (effective Aug 1, 2023) — civil remedies include damages, disgorgement of profits, a civil penalty up to $10,000, attorney fees, injunctive relief, and a private right of action. (3) Minn. Stat. § 325E.91 (HF 1606; signed May 8, 2026; effective Aug 1, 2026) bans AI "nudification technology" — Attorney-General-enforced civil penalty up to $500,000 per unlawful access/download/use plus a private right of action. The Minnesota Consumer Data Privacy Act (effective July 31, 2025) adds binding profiling/automated-decision rights. Counsel should confirm statutory citations, penalty tiers, the § 609.771 litigation posture, and the § 325E.91 Aug 1, 2026 effective date against the enacted text. legal_review_pending.

FTC Act § 5 applies to all Minnesota businesses using AI. Minnesota Consumer Fraud Act (Minn. Stat. § 325F.69) may independently apply to deceptive AI claims — Minnesota AG has pursued algorithmic deception cases. Ensure AI chatbots disclose their nature, AI-generated product claims are truthful, and AI pricing does not exploit consumers.

Minnesota has some of the strongest state labor protections in the US. EEOC May 2023 guidance requires employers to test AI employment tools for disparate impact. Minnesota's large healthcare employers (Mayo Clinic, M Health), retail (Target, Best Buy), and financial services companies using AI hiring or scheduling tools must document adverse impact analyses. Minnesota Human Rights Act (MHRA) independently prohibits AI that discriminates in employment.

Minnesota's financial services sector (U.S. Bancorp, Ameriprise, TCF Bank) using AI for credit and investment decisions must comply with FCRA adverse action notice requirements. CFPB Circular 2022-03 requires specific adverse action reasons from the consumer's file. CFPB has actively examined Minnesota banks for AI fair lending compliance under the Equal Credit Opportunity Act (ECOA).

Minnesota is home to Mayo Clinic, one of the world's leading healthcare AI research and deployment centers. AI systems processing Protected Health Information must comply with HIPAA Security and Privacy Rules. AI diagnostic and clinical decision support tools meeting FDA's SaMD definition require FDA clearance. Mayo Clinic's AI deployments are closely watched by FDA — Minnesota healthcare AI companies should implement equivalent standards.

Minnesota is very likely to enact AI consumer protection legislation. Monitor revisor.mn.gov. SF 1886 / HF 2690 had broad bipartisan support — substantially similar bills are expected in 2025-2026. Minnesota AG has publicly stated that Minnesota Consumer Fraud Act already applies to deceptive AI.