Regulon — US-HR-7218 · US HR 7218 (CHAT Act — Companion AI Chatbot Minor Protections)

WHAT THIS BILL REGULATES · 4 REQUIREMENT TYPES

How Is This Bill Enforced

Enforcement Authority

Federal Trade Commission enforcement. Violations are treated as unfair or deceptive acts or practices under section 18(a)(1)(B) of the FTC Act. The FTC enforces using the same jurisdiction, powers, and duties as under the FTC Act. State attorneys general may also bring civil actions as parens patriae on behalf of state residents; the AG must provide prior written notice to the FTC unless not feasible. The FTC may intervene in state actions. During pendency of a Commission action, states may not institute parallel actions against the same defendant for the same violation. A safe harbor applies if the covered entity demonstrates good-faith reliance on user-provided age information, compliance with FTC guidance, and reasonable conformity to widely accepted industry standards or FTC-identified best practices for age verification.

Private Right of Action

No private right of action. Enforcement is exclusive to the designated authority.

Penalties

Penalties and remedies are those provided under the Federal Trade Commission Act (15 U.S.C. 41 et seq.). State attorneys general may seek injunctive relief, damages, restitution, or other compensation on behalf of residents, or such other relief as the court considers appropriate. No statutory minimum or maximum specific to this Act.

Verbatim statutory text on the left; plain-language analysis and a per-section checklist on the right. Numbered markers cross-link to the matching checklist row.

Statutory Text

Analysis & Obligations

Sec. 1

Short title

This Act may be cited as the ''Children Harmed by AI Technology Act'' or the ''CHAT Act''.

This section establishes the short title of the Act as the "Children Harmed by AI Technology Act" or the "CHAT Act." It creates no compliance obligations.

Sec. 2

Definitions

(1) COMMISSION.—The term ''Commission'' means the Federal Trade Commission.

(2) COMPANION AI CHATBOT.—The term ''companion AI chatbot''— (A) means any software-based artificial intelligence system or program that exists for the primary purpose of simulating emotional interaction, friendship, companionship, or therapeutic communication with a user; and (B) does not include the following: (i) A bot that is used only for customer service, a business operational purpose, productivity and analysis related to source information, internal research, or technical assistance. (ii) A bot that is a feature of a video game and is limited to replies related to the video game that cannot discuss topics related to mental health, self-harm, sexually explicit conduct, or maintain a dialogue on other topics unrelated to the video game. (iii) A stand-alone consumer electronic device that functions as a speaker and voice command interface, acts as a voice-activated virtual assistant, and does not sustain a relationship across multiple interactions or generate outputs that are likely to elicit emotional responses in the user.

(3) COVERED ENTITY.—The term ''covered entity'' means any person that owns, operates, or otherwise makes available a companion AI chatbot to individuals in the United States.

(4) MINOR.—The term ''minor'' means any individual that has not attained 18 years of age.

(5) POPUP.—The term ''popup'' means a visible notification on the screen of a user that can be resolved if interacted with by the user.

(6) SEXUALLY EXPLICIT COMMUNICATION.—The term ''sexually explicit communication'' includes any content, conversation, or material that describes, depicts, or encourages sexually explicit conduct, as defined in paragraph (2)(B) of section 2256 of title 18, United States Code.

(7) SUICIDAL IDEATION.—The term ''suicidal ideation'' means, with respect to an interaction between a minor and a companion AI chatbot, any dialogue in which such minor expresses thoughts of self-harm or suicide.

Section 2 defines the key terms used throughout the Act. The central defined terms are companion AI chatbot — scoped to AI systems whose primary purpose is simulating emotional interaction, friendship, companionship, or therapeutic communication — and covered entity, which captures any person that owns, operates, or makes available such a chatbot to U.S. individuals. The definition of companion AI chatbot contains three explicit carve-outs: customer-service and business-operational bots, in-game video game bots that cannot discuss mental health, self-harm, or sexually explicit topics, and standalone voice-command devices that do not sustain multi-session relationships. The definition of suicidal ideation is notably limited to interactions between a minor and a companion AI chatbot, which may narrow the monitoring obligation in Section 3(e) even though that section's text applies to all users.

Sec. 3

Covered entity obligations

Deployer

(a) 1 CREATION OF USER ACCOUNTS.—A covered entity shall require each individual accessing a companion AI chatbot to make a user account in order to use or otherwise interact with such chatbot.

(b)(1) 2 AGE VERIFICATION OF EXISTING ACCOUNTS.—With respect to each user account of a companion AI chatbot that exists as of the date described in section 7, a covered entity shall— (A) on such date, freeze any such account; (B) in order to restore the functionality of such account, require that the user provide age information that is verifiable using a commercially available method or process that is reasonably designed to ensure accuracy; and (C) using such age information, classify each user as a minor or an adult.

(b)(2) 2 AGE VERIFICATION OF NEW ACCOUNTS.—At the time an individual creates a new user account to use or interact with a companion AI chatbot, a covered entity shall— (A) request age information from the individual; and (B) verify the individual's age using a commercially available method or process that is reasonably designed to ensure accuracy.

(c)(1)–(2) 3 MINOR ACCOUNT PROTECTIONS.—If the age verification process described in subsection (b) determines that a user is a minor, a covered entity shall— (1) require the account of such user to be affiliated with a parental account, which such covered entity has verified using a commercially available method or process that is reasonably designed to ensure accuracy; (2) obtain verifiable parental consent from the holder of the account before allowing a minor to access and use the companion AI chatbot;

(c)(3) 4 immediately inform the holder of the parental account of any interaction involving suicidal ideation;

(c)(4) 5 block the minor's access to any companion AI chatbot that engages in sexually explicit communication.

(d) 6 CONFIDENTIALITY OF AGE VERIFICATION DATA.—A covered entity shall protect the confidentiality of age information provided by a user for age verification by limiting the collection, processing, use, and storage of such information to what is strictly necessary to verify a user's age, obtain verifiable parental consent, or maintain compliance records.

(e) 7 MONITORING FOR SUICIDAL IDEATION.—A covered entity shall monitor companion AI chatbot interactions for suicidal ideation and, in response to any such interaction, provide to the user and the parental account affiliated with such user appropriate resources by presenting contact information for the National Suicide Prevention Lifeline.

(f) 8 NOTIFICATION OF ARTIFICIAL CHATBOT.—At the beginning of any interaction between a user and a companion AI chatbot, and not less frequently than every 60 minutes during such interaction thereafter, a covered entity shall display to such user a clear popup that notifies the user that they are not engaging in dialogue with a human counterpart.

Section 3 is the bill's operative core, imposing six distinct categories of obligation on covered entities: mandatory account creation for all users, age verification for both existing and new accounts, minor-specific account protections (parental affiliation, parental consent, suicidal ideation notification, and sexually explicit content blocking), age-verification data minimization, monitoring for suicidal ideation with crisis referral, and AI-identity disclosure at session start and every 60 minutes thereafter.

The age verification framework distinguishes between existing accounts (which must be frozen and re-verified on the effective date) and new accounts (which must be verified at creation). The minor protections are triggered by the verification result and require parental account affiliation, verifiable parental consent, immediate parental notification of any suicidal ideation interaction, and blocking of sexually explicit companion chatbot content. The suicidal-ideation monitoring obligation in subsection (e) applies to all users and their affiliated parental accounts but references the defined term suicidal ideation, which is itself limited to minor interactions — a potential ambiguity. The AI-identity popup disclosure in subsection (f) applies to all users, not just minors.

Compliance actions 8 items

Covered entities must require every individual accessing a companion AI chatbot to create a user account before using or interacting with the chatbot.

MN-01.1

Covered entities must implement age verification for all companion AI chatbot users — freezing existing accounts on the effective date and requiring verified age information to restore them, and verifying age at account creation for new users — using a commercially available method reasonably designed to ensure accuracy, and must classify each user as a minor or an adult.

MN-01.1

Covered entities must, for any user determined to be a minor, (1) require the minor's account to be affiliated with a verified parental account, and (2) obtain verifiable parental consent from the parental account holder before allowing the minor to access the companion AI chatbot.

MN-01.2

Covered entities must immediately inform the holder of the affiliated parental account of any interaction involving suicidal ideation by a minor user.

MN-01.10

Covered entities must block minor users from accessing any companion AI chatbot that engages in sexually explicit communication.

MN-01.6

Covered entities must limit the collection, processing, use, and storage of age verification information to what is strictly necessary to verify a user's age, obtain verifiable parental consent, or maintain compliance records.

D-01.4

Covered entities must monitor companion AI chatbot interactions for suicidal ideation and, upon detecting such an interaction, provide the user and the affiliated parental account with contact information for the National Suicide Prevention Lifeline.

S-04.1

Covered entities must display to every user a clear popup at the beginning of any companion AI chatbot interaction — and at least every 60 minutes during such interaction thereafter — notifying the user that they are not engaging in dialogue with a human counterpart.

T-01.1

Sec. 4

Compliance guidance and enforcement limitations

(a) IN GENERAL.—Not later than 180 days after the date of enactment of this Act, the Commission shall issue guidance to assist covered entities in complying with the requirements of this Act.

(b) LIMITATION.—In any enforcement action brought pursuant to this Act, the Commission shall allege a specific violation of a provision of this Act. The Commission may not base an enforcement action on, or execute a consent order based on, practices that are alleged to be inconsistent with any guidance issued by the Commission with respect to this Act, unless the practices are alleged to violate a provision of this Act. A person may use such guidance as evidence of compliance with this Act.

Section 4 directs the FTC to issue compliance guidance within 180 days of enactment and limits the Commission's enforcement authority to specific statutory violations — the FTC may not bring enforcement actions based solely on inconsistency with its own guidance unless the practices independently violate a provision of the Act. Covered entities may use FTC guidance as evidence of compliance, creating a soft safe harbor for entities that follow the guidance.

Sec. 5

Enforcement

(a)(1) UNFAIR OR DECEPTIVE ACTS OR PRACTICES.—A violation of this Act or a regulation promulgated under this Act shall be treated as a violation of a rule defining an unfair or deceptive act or practice under section 18(a)(1)(B) of the Federal Trade Commission Act (15 U.S.C. 57a(a)(1)(B)).

(a)(2)(A)–(C) POWERS OF THE COMMISSION.— (A) IN GENERAL.—The Commission shall enforce this Act in the same manner, by the same means, and with the same jurisdiction, powers, and duties as though all applicable terms and provisions of the Federal Trade Commission Act (15 U.S.C. 41 et seq.) were incorporated into and made a part of this Act. (B) PRIVILEGES AND IMMUNITIES.—Any person who violates this Act or a regulation promulgated under this Act shall be subject to the penalties and entitled to the privileges and immunities provided in the Federal Trade Commission Act (15 U.S.C. 41 et seq.). (C) AUTHORITY PRESERVED.—Nothing in this section shall be construed to limit the authority of the Commission under any other provision of law.

(b)(1)–(5) ENFORCEMENT BY STATES.— (1) IN GENERAL.— (A) CIVIL ACTIONS.—In any case in which the attorney general of a State has reason to believe that an interest of the residents of that State has been or is threatened or adversely affected by the engagement of any person in a practice that violates this Act, the State, as parens patriae, may bring a civil action on behalf of the residents of the State in a district court of the United States of appropriate jurisdiction to— (i) enjoin that practice; (ii) enforce compliance with the requirements of this Act; (iii) obtain damages, restitution, or other compensation on behalf of residents of the State; or (iv) obtain such other relief as the court may consider to be appropriate. (B) NOTICE.— (i) IN GENERAL.—Before filing an action under subparagraph (A), the attorney general of the State involved shall provide to the Commission— (I) a written notice of that action; and (II) a copy of the complaint for that action. (ii) EXEMPTION.— (I) IN GENERAL.—Clause (i) shall not apply with respect to the filing of an action by an attorney general of a State under this subsection if the attorney general determines that it is not feasible to provide the notice described in that clause before the filing of the action. (II) NOTIFICATION.—In an action described in subclause (I), the attorney general of a State shall provide notice and a copy of the complaint to the Commission at the same time as the attorney general files the action. (2) INTERVENTION.— (A) IN GENERAL.—On receiving notice under paragraph (1)(B), the Commission shall have the right to intervene in the action that is the subject of the notice. (B) EFFECT OF INTERVENTION.—If the Commission intervenes in an action under paragraph (1), it shall have the right— (i) to remove the action to the appropriate district court of the United States; (ii) to be heard with respect to any matter that arises in that action; and (iii) to file a petition for appeal. (3) CONSTRUCTION.—For purposes of bringing any civil action under paragraph (1), nothing in this Act shall be construed to prevent an attorney general of a State from exercising the powers conferred on the attorney general by the laws of that State to— (A) conduct investigations; (B) administer oaths or affirmations; or (C) compel the attendance of witnesses or the production of documentary and other evidence. (4) ACTIONS BY THE COMMISSION.—In any case in which an action is instituted by or on behalf of the Commission for a violation of this Act, no State may, during the pendency of that action, institute an action under paragraph (1) against any defendant named in the complaint in that action for such violation. (5) VENUE; SERVICE OF PROCESS.— (A) VENUE.—Any action brought under paragraph (1) may be brought in— (i) the district court of the United States that meets applicable requirements relating to venue under section 1391 of title 28, United States Code; or (ii) a State court of competent jurisdiction. (B) SERVICE OF PROCESS.—In an action brought under paragraph (1), process may be served in any district in which the defendant— (i) is an inhabitant; or (ii) may be found.

Section 5 establishes a dual enforcement framework. The FTC treats violations as unfair or deceptive acts or practices under Section 18(a)(1)(B) of the FTC Act, with full FTC Act enforcement powers, penalties, privileges, and immunities. State attorneys general may bring civil actions as parens patriae in federal or state court to enjoin violations, enforce compliance, and obtain damages or restitution on behalf of state residents. State AGs must provide prior written notice and a copy of the complaint to the FTC before filing, except when not feasible. The FTC may intervene in state actions. During the pendency of a Commission action, no state may institute a parallel action against the same defendant for the same violation. The savings clause preserves existing FTC authority and state investigatory powers.

Sec. 6

Safe harbor

A covered entity is deemed not liable for a violation of this Act if the covered entity demonstrates it has— (1) relied in good faith on age information provided by a user of the companion AI chatbot for purposes of verifying the age of such user; (2) complied with the guidance described in section 4; and (3) reasonably conformed to widely accepted industry standards or best practices, or to standards or best practices identified by the Commission, for age verification and applied those standards or best practices consistently and in good faith.

Section 6 creates an affirmative safe harbor for covered entities. A covered entity is deemed not liable for a violation of the Act if it demonstrates three elements: (1) good-faith reliance on user-provided age information, (2) compliance with FTC guidance issued under Section 4, and (3) reasonable conformity to widely accepted industry standards or best practices — or to standards identified by the FTC — for age verification, applied consistently and in good faith. This provision operates as a defense modifying the enforcement provisions in Section 5 rather than as an independent compliance obligation.

Sec. 7

Effective date

This Act shall take effect on the date that is 1 year after the date of enactment of this Act.

Section 7 provides that the Act takes effect one year after the date of enactment. This delayed effective date gives covered entities a compliance runway and is also the trigger date for the freeze-and-verify obligation on existing accounts under Section 3(b)(1).

Minor Safety Parental consent · controls · termination workflows

5 items

MN-01.1

Covered entities must require every individual accessing a companion AI chatbot to create a user account before using or interacting with the chatbot.

MN-01.1

MN-01.2

MN-01.10

Covered entities must immediately inform the holder of the affiliated parental account of any interaction involving suicidal ideation by a minor user.

MN-01.6

Covered entities must block minor users from accessing any companion AI chatbot that engages in sexually explicit communication.

Transparency AI identity disclosure · periodic reminders

1 item

T-01.1