Regulon — US-SB-5154 · US S. 5154 (CHAT Act 2.0

WHAT THIS BILL REGULATES · 7 REQUIREMENT TYPES

How Is This Bill Enforced

Enforcement Authority

Enforced by the Federal Trade Commission, treating violations as unfair or deceptive acts or practices under Section 18(a)(1)(B) of the FTC Act with full FTC Act powers and rulemaking authority. State attorneys general may bring parens patriae civil actions in federal district court on behalf of state residents after notifying the Commission, which has a right to intervene and remove. No private right of action for individuals.

Private Right of Action

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

Penalties

FTC enforcement carries FTC Act penalties and remedies. State attorneys general may obtain injunctive relief, damages, restitution or other compensation on behalf of residents, and such other relief as the court considers appropriate. No specified statutory penalty amount and no attorney fee provision.

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 2.0’’ or the ‘‘CHAT Act 2.0’’.

Names the Act the Children Harmed by AI Technology Act 2.0 or CHAT Act 2.0. No operative obligation.

Sec. 2

Definitions

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

(2)(A) COMPANION AI CHATBOT.—(A) IN GENERAL.—The term ''companion AI chatbot''— (i) means any software-based artificial intelligence system or program that exists for— (I) primarily educational purposes, including tutoring; or (II) the primary purpose of simulating interpersonal or emotional interaction, friendship, companionship, or therapeutic communication with a user across multiple interactions; and (ii) does not include any chatbot that— (I) does not have a memory function or the ability to maintain a conversation based on information a user has provided in prior responses, including a virtual assistant or other chatbot with pre-programmed responses; or (II) has the ability to maintain a conversation based on information a user has provided in prior responses but is programmed for a highly specialized and narrow task, including— (aa) a customer service chatbot; (bb) a business operation chatbot; (cc) a productivity, research, or analytical chatbot; (dd) a standalone voice assistant that— (AA) does not sustain relationships across multiple interactions; and (BB) is not designed to elicit emotional responses; or (ee) a video game chatbot that is— (AA) limited to replies related to the video game; and (BB) not capable of discussing topics unrelated to the video game or topics related to mental health, suicidal ideation, or sexually explicit communication.

(2)(B) TIERS.—The term ''companion AI chatbot'' includes the following tiers: (i) TIER I.—A ''tier I companion AI chatbot'' is a companion AI chatbot that is— (I) marketed, or reasonably used, for primarily educational purposes, including tutoring; and (II) not capable of— (aa) offering companionship to, or therapeutic communication with, a user; or (bb) otherwise creating a strong parasocial attachment with a user. (ii) TIER II.—A ''tier II companion AI chatbot'' is a companion AI chatbot that is— (I) marketed, or reasonably used, for the primary purpose of simulating interpersonal or emotional interaction, friendship, or companionship; and (II) not used for mental health treatment, emotional disorders, therapeutic communication, or other quasi-therapeutic support. (iii) TIER III.—A ''tier III companion AI chatbot''— (I) is a companion AI chatbot that is marketed, or reasonably used, for mental health treatment, emotional disorders, therapeutic communication, or other quasi-therapeutic support; and (II) includes any AI companion chatbot that— (aa) simulates a therapeutic relationship, such as a ''trauma coach'' or ''AI therapist''; and (bb) collects and acts on detailed mental-health data, including diagnoses, treatment plans, medication references, or self-harm plans.

(3) CHILD SEXUAL ABUSE MATERIAL.—The term ''child sexual abuse material'' has the meaning given the term ''child pornography'' in section 2256 of title 18, United States Code.

(4) 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.

(5)–(11) MINOR.—The term ''minor'' means any individual that has not attained 18 years of age. (6) MINOR USER.—The term ''minor user'' means a user that is a minor. (7) NUDGE-OUT NOTIFICATION.—The term ''nudge-out notification'' means a popup that gives a reminder to a user to take a break from using the companion AI chatbot for a specified period of time. (8) POPUP.—The term ''popup'' means a visible notification on the screen of a user that can be resolved if interacted with by the user. (9) 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. (10) SUICIDAL IDEATION.—The term ''suicidal ideation'' means, with respect to an interaction between a minor user and a companion AI chatbot, any dialogue in which such minor user expresses thoughts of self-harm or suicide. (11) USER.—The term ''user'' means any individual who establishes an account for the use of a companion AI chatbot.

Defines the terms that scope the Act, most importantly companion AI chatbot and its three tiers. The definition is unusually broad on the front end — it captures software AI that exists for primarily educational/tutoring purposes as well as for simulating companionship or therapeutic communication — but is narrowed by carve-outs for memoryless chatbots and highly specialized/narrow-task tools (customer service, business, productivity, standalone voice assistants, and video-game chatbots).

The tier structure (Tier I educational, Tier II social/companionship, Tier III mental-health/therapeutic) drives the differentiated obligations in Sections 5–7. The definitions also fix the key threshold term minor at under 18 and define covered entity to reach any person making a companion AI chatbot available to individuals in the United States.

Sec. 3

Covered Entity Obligations

DeployerDeveloper

(1)–(6) 1 Each covered entity shall take reasonable measures to prevent a companion AI chatbot from— (1) encouraging or normalizing self-harm, suicide, or physical violence; (2) engaging in sexually explicit communication with a minor user; (3) misleading a minor user into believing such chatbot is a human; (4) claiming to be a licensed medical or mental health professional; (5) creating emotional dependency, simulating a romantic relationship with a minor user, or engaging in conduct reasonably likely to cause a minor user to believe such chatbot is an emotional partner; or (6) facilitating the promotion, creation, solicitation, or distribution of child sexual abuse material.

Imposes a baseline duty on every covered entity to take reasonable measures to prevent its companion AI chatbot from producing a defined set of harmful behaviors: encouraging or normalizing self-harm, suicide, or physical violence; engaging in sexually explicit communication with a minor user; misleading a minor user into believing the chatbot is human; claiming to be a licensed professional; creating emotional dependency or simulating a romantic relationship with a minor user; or facilitating CSAM.

These are output-restriction and prohibited-conduct duties combining self-harm content controls, minor sexual-content controls, CSAM prohibition, and a deceptive-relationship prohibition. Note the mixed scope — some prongs run to all users (self-harm, CSAM) while others are expressly limited to minor users.

Compliance actions 1 item

Covered entities must take reasonable measures to prevent their companion AI chatbot from encouraging self-harm, suicide, or violence; engaging in sexually explicit communication with minors; claiming to be human or a licensed professional; simulating romantic relationships or emotional dependency with minors; or facilitating CSAM.

S-02.4

Sec. 4

Requirements of All Companion AI Chatbots

Deployer

(a)(1)–(2) 2 AGE ASSURANCE REQUIREMENT.— (1) ACCOUNT REQUIREMENT.—Each covered entity shall require each individual accessing a companion AI chatbot to establish an account. (2) AGE ASSURANCE REQUIREMENT.—A covered entity shall require an individual seeking to establish an account to access a companion AI chatbot to provide an age assurance that includes the age and date of birth of such individual.

(a)(3) 3 CHILD-PROTECTIVE SETTINGS REQUIREMENT.— (A) IN GENERAL.—If the age assurance described in paragraph (2) indicates that an individual seeking to establish an account is a minor, a covered entity shall require that for an account to be established— (i) such minor, or a parent or legal guardian of such minor, provides contact information for a parent or legal guardian of such minor; and (ii) the child-protective settings described in subparagraph (B) are enabled for the account of such minor. (B) CHILD-PROTECTIVE SETTINGS.—A covered entity shall ensure that the child-protective settings enabled pursuant to subparagraph (A)(ii) include— (i) easy-to-use parental controls that allow a parent or legal guardian of a minor user to monitor and limit such minor user's use of a companion AI chatbot; and (ii) a system for notifying the parent or legal guardian of a minor user if such minor user expresses suicidal ideation while using a companion AI chatbot.

(b)(1)–(2) 4 AI IDENTITY DISCLOSURE.— (1) IN GENERAL.—A covered entity shall require a companion AI chatbot to provide to each minor user of such chatbot a clear and conspicuous disclosure that meets the requirements described in paragraph (2) that such chatbot is not human. (2) DISCLOSURE REQUIREMENTS.—A disclosure provided pursuant to paragraph (1) shall be— (A) provided at the beginning of an interaction between the companion AI chatbot and a minor user of such chatbot; and (B) written in plain language.

Sets the universal gating requirements that apply to every companion AI chatbot regardless of tier. Every covered entity must require account creation and an age assurance that includes age and date of birth, and where the age assurance indicates a minor, must obtain a parent/guardian contact and enable child-protective settings — including easy-to-use parental controls and a system to notify the parent or guardian if the minor expresses suicidal ideation.

Separately, the section requires a plain-language, clear-and-conspicuous AI identity disclosure to each minor user at the beginning of an interaction that the chatbot is not human.

Compliance actions 3 items

Covered entities must require every user to create an account and provide an age assurance including age and date of birth, and must obtain parent or guardian contact information before establishing a minor's account.

MN-01.1

Covered entities must enable child-protective settings for minor accounts, including easy-to-use parental controls to monitor and limit use and a system to notify the parent or guardian when the minor expresses suicidal ideation.

MN-01.3

Covered entities must provide each minor user a clear and conspicuous, plain-language disclosure at the beginning of an interaction that the companion AI chatbot is not human.

T-01.1

Sec. 5

Requirements of Tier I Companion AI Chatbots

Deployer

(1) 5 A covered entity shall— (1) require a tier I companion AI chatbot to provide a disclosure described in section 4(b) not less frequently than every 3 hours during a continuing interaction between such chatbot and a minor user; and (2) prohibit a tier I companion AI chatbot from claiming to be a human or a licensed professional in any field to a minor user.

(2) 6 prohibit a tier I companion AI chatbot from claiming to be a human or a licensed professional in any field to a minor user.

Adds two Tier I-specific duties on top of the universal Section 4 requirements: a periodic (at least every 3 hours) repeat of the section 4(b) AI identity disclosure during a continuing interaction with a minor user, and a flat prohibition on the Tier I chatbot claiming to be a human or a licensed professional in any field to a minor user.

Compliance actions 2 items

Covered entities must have a Tier I companion AI chatbot repeat the not-human disclosure to a minor user at least every 3 hours during a continuing interaction.

T-01.2

Covered entities must prohibit a Tier I companion AI chatbot from claiming to be a human or a licensed professional in any field to a minor user.

T-01.3

Sec. 6

Requirements of Tier II Companion AI Chatbots

Deployer

(1) 7 A covered entity that makes available a tier II companion AI chatbot shall comply with the following requirements: (1) DISCLOSURE AND USE LIMITS.—A covered entity shall require a tier II companion AI chatbot to provide— (A) a disclosure not less frequently than every 60 minutes during a continuing interaction between such chatbot and a minor user that the chatbot is not a human or licensed professional in any field; and (B) a nudge-out notification not less frequently than every 90 minutes during any such interaction.

(2) 8 CRISIS ESCALATION PROTOCOLS.—A covered entity that makes available a tier II companion AI chatbot shall— (A) maintain, publish on a publicly available website in clear, accessible language, and require such companion AI chatbot to follow, evidence-based protocols designed to— (i) detect expressions of suicidal ideation or self-harm; and (ii) refer minor users to— (I) the 988 Suicide & Crisis Lifeline; and (II) other appropriate crisis service providers; and (B) prohibit such companion AI chatbot from providing crisis counseling or de-escalation services to any minor user.

(3) 9 PARENTAL NOTIFICATION.—If a minor user expresses suicidal ideation while engaging with a tier II companion AI chatbot, the covered entity shall notify the parent or guardian of such minor user without unreasonable delay.

(4) 10 PROHIBITION ON PERSISTENT MEMORY.— (A) IN GENERAL.—Subject to subparagraph (B), a covered entity shall prohibit a tier II companion AI chatbot from maintaining any memory or history of any previous interaction with a minor user. (B) EXCEPTION.—A tier II companion AI chatbot may maintain such information as is necessary to ensure compliance with this Act.

Imposes heightened obligations on covered entities offering Tier II (social/companionship) chatbots. Disclosure cadence tightens to at least every 60 minutes, plus a nudge-out take-a-break notification at least every 90 minutes. Entities must maintain, publish on a public website, and require the chatbot to follow evidence-based crisis-escalation protocols that detect suicidal ideation or self-harm and refer minor users to the 988 Suicide & Crisis Lifeline and other crisis providers, while prohibiting the chatbot from providing crisis counseling or de-escalation itself.

The section also requires parental/guardian notification without unreasonable delay when a minor expresses suicidal ideation, and prohibits Tier II chatbots from maintaining any memory or history of prior interactions with a minor user, except as needed for Act compliance.

Compliance actions 4 items

Covered entities must have a Tier II companion AI chatbot disclose to a minor user at least every 60 minutes that it is not human or a licensed professional, and deliver a take-a-break nudge-out notification at least every 90 minutes during continuing interactions.

T-01.2

Covered entities offering a Tier II companion AI chatbot must maintain, publish on a public website, and require the chatbot to follow evidence-based protocols that detect suicidal ideation or self-harm and refer minor users to the 988 Lifeline and other crisis providers, and must prohibit the chatbot from providing crisis counseling or de-escalation to minors.

S-04.1

Covered entities must notify a minor user's parent or guardian without unreasonable delay when the minor expresses suicidal ideation while using a Tier II companion AI chatbot.

MN-01.10

Covered entities must prohibit a Tier II companion AI chatbot from maintaining any memory or history of prior interactions with a minor user, except information necessary to ensure compliance with the Act.

D-01.9

Sec. 7

Requirements of Tier III Companion AI Chatbots

Deployer

(1) 11 A covered entity shall— (1) prohibit the use of a tier III companion AI chatbot by a minor user unless such use is supervised by a licensed medical or mental health professional;

(2) 12 require such a companion AI chatbot to— (A) provide a disclosure not less frequently than every 60 minutes during a continuing interaction between such chatbot and a minor user that the chatbot is not a human or licensed professional in any field; (B) provide a nudge-out notification not less frequently than every 60 minutes during any such interaction; (C) maintain, publish on a publicly available website in clear, accessible language, and require such companion AI chatbot to follow, evidence-based protocols designed to— (i) detect expressions of suicidal ideation or self-harm; (ii) refer minor users to— (I) the 988 Suicide & Crisis Lifeline; (II) licensed medical and mental health professionals; and (III) other appropriate crisis service providers; and (iii) prohibit such companion AI chatbot from providing crisis counseling or de-escalation services to any minor user; and (D) notify the parent or guardian of a minor user without unreasonable delay if such minor user expresses suicidal ideation.

(3) 13 prohibit a tier III companion AI chatbot from— (A) providing a minor user with any diagnosis or treatment decision; and (B) functioning as a standalone provider of professional mental-health care; and

(4) 14 establish and maintain a risk management program for tier III companion AI chatbots containing written policies providing for employees of such entity to— (A) continually monitor such chatbots; (B) become familiar with crisis de-escalation measures; and (C) engage in recordkeeping regarding such chatbots.

Imposes the most stringent obligations on Tier III (mental-health/therapeutic) chatbots. Minor use is prohibited unless supervised by a licensed medical or mental health professional. The chatbot must give a not-human/not-licensed-professional disclosure and a nudge-out notification at least every 60 minutes, maintain and publish evidence-based crisis-detection-and-referral protocols (routing minors to the 988 Lifeline, licensed professionals, and other crisis providers), refrain from providing crisis counseling or de-escalation itself, and notify a parent or guardian without unreasonable delay on suicidal ideation.

Tier III chatbots are barred from providing any diagnosis or treatment decision and from functioning as a standalone provider of professional mental-health care. Covered entities must also establish and maintain a written risk management program requiring employees to continually monitor the chatbots, understand crisis de-escalation measures, and keep records.

Compliance actions 4 items

Covered entities must prohibit a minor from using a Tier III (mental-health/therapeutic) companion AI chatbot unless the use is supervised by a licensed medical or mental health professional.

HC-02.3

Covered entities offering a Tier III companion AI chatbot must require 60-minute not-human/not-licensed disclosures and nudge-out notifications, maintain and publish evidence-based crisis protocols that refer minors to the 988 Lifeline, licensed professionals, and crisis providers while barring the chatbot from providing crisis counseling itself, and notify a parent or guardian without unreasonable delay on suicidal ideation.

S-04.1

Covered entities must prohibit a Tier III companion AI chatbot from providing a minor with any diagnosis or treatment decision and from functioning as a standalone provider of professional mental-health care.

HC-02.2

Covered entities offering a Tier III companion AI chatbot must establish and maintain a written risk management program requiring employees to continually monitor the chatbots, understand crisis de-escalation measures, and engage in recordkeeping.

G-01.1

Sec. 8

Study on Impact of Tier II and Tier III Companion AI Chatbots

(a)–(b) STUDY REQUIRED.—The Director of the National Institute of Standards and Technology shall conduct a study to assess the impact of tier II and tier III companion AI chatbots on the matters specified in subsection (b). (b) MATTERS SPECIFIED.—The matters specified in this subsection are adverse outcomes relating to the following: (1) Self-harm and suicide. (2) Manipulation and emotional dependency. (3) Exploitation of minor users.

Directs the Director of the National Institute of Standards and Technology to study adverse outcomes of Tier II and Tier III companion AI chatbots relating to self-harm and suicide, manipulation and emotional dependency, and exploitation of minor users. This is a government-study mandate that imposes no compliance obligation on covered entities.

Sec. 9

Data Protections

DeployerDeveloper

(a)(1) 15 PROHIBITION ON CHILD-TARGETED ADVERTISING AND THE SALE OR SHARING OF DATA OF MINOR USERS WITHOUT PARENTAL CONSENT.— (1) TARGETED ADVERTISING.—A covered entity shall not engage in targeted advertising to a minor user based on the conversational content, inferred emotional state, or behavioral profiling collected during an interaction between such minor user and a companion AI chatbot.

(a)(2) 16 SALE OR SHARING OF DATA OF MINORS.—A covered entity shall not sell, share, or otherwise transfer the data of a minor user to any third party without verifiable parental consent.

(b) 17 DOCUMENTATION MAINTENANCE.—Each covered entity that makes available a tier III companion AI chatbot shall— (1) maintain documentation regarding— (A) the data utilized to train such chatbot; and (B) how such chatbot collects data from a minor user; and (2) require such chatbot to comply with requirements and safeguards regarding health privacy, as determined to be appropriate by the Commission.

(c) 18 DELETION OF CONVERSATION HISTORY.—Each covered entity shall provide to a minor user— (1) a simple, accessible mechanism within a companion AI chatbot through which the minor user can delete the conversation history between the minor user and the companion AI chatbot; (2) clear instructions for using such mechanism; and (3) a confirmation within a reasonable period of time that the entity has deleted the conversation history of the minor user pursuant to paragraph (1).

Restricts data practices affecting minor users. Covered entities may not engage in targeted advertising to a minor user based on conversational content, inferred emotional state, or behavioral profiling from chatbot interactions, and may not sell, share, or transfer a minor user's data to any third party without verifiable parental consent.

Covered entities offering Tier III chatbots must maintain documentation of the training data and how the chatbot collects data from minor users, and must comply with health-privacy safeguards as the Commission determines appropriate. Every covered entity must also give minor users a simple, accessible mechanism (with clear instructions and confirmation) to delete their conversation history.

Compliance actions 4 items

Covered entities must not engage in targeted advertising to a minor user based on conversational content, inferred emotional state, or behavioral profiling collected during a companion AI chatbot interaction.

MN-01.7

Covered entities must not sell, share, or otherwise transfer a minor user's data to any third party without verifiable parental consent.

D-01.6

Covered entities offering a Tier III companion AI chatbot must maintain documentation of the data used to train the chatbot and how it collects data from minor users, and must require the chatbot to comply with Commission-determined health-privacy safeguards.

G-01.3

Covered entities must give minor users a simple, accessible in-product mechanism to delete their conversation history, with clear instructions and confirmation of deletion within a reasonable time.

D-01.6

Sec. 10

Enforcement

(a) ENFORCEMENT BY THE COMMISSION.— (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)). (2) POWERS OF THE COMMISSION.— (A) IN GENERAL.—The Commission shall enforce this Act or a regulation promulgated under 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 Act shall be construed to limit the authority of the Commission under any other provision of law. (D) RULEMAKING.—The Commission may promulgate in accordance with section 553 of title 5, United States Code, such rules as may be necessary to carry out this Act.

(b) 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.

Establishes the enforcement architecture. Violations are treated as unfair or deceptive acts or practices under Section 18(a)(1)(B) of the FTC Act, and the Commission enforces with full FTC Act jurisdiction, powers, penalties, and Section 553 rulemaking authority. Separately, state attorneys general may bring parens patriae civil actions in federal district court to enjoin violations, enforce compliance, and obtain damages, restitution, or other relief, subject to advance notice to the Commission and the Commission's right to intervene, remove, and appeal.

This section creates no independent compliance obligation on covered entities; it defines who enforces and how.

Sec. 11

Annual Reports

Not later than 1 year after the effective date described in section 13, and annually thereafter, the Commission shall publish a report regarding— (1) the compliance of covered entities with sections 6 and 7; and (2) any observed risks and recommended best practices regarding each tier of companion AI chatbots.

Requires the Commission to publish, within one year of the effective date and annually thereafter, a report on covered-entity compliance with Sections 6 and 7 and on observed risks and recommended best practices for each tier of companion AI chatbots. This is a Commission reporting duty, not a covered-entity obligation.

Sec. 12

Rules of Construction

(1)–(3) Nothing in this Act shall be construed to— (1) limit or supersede the obligations of a covered entity under any other Federal or State law relating to the privacy or security of personal information, except to the extent such law is inconsistent with this Act; (2) require a covered entity to proactively monitor every interaction between a user and a companion AI chatbot beyond the requirements expressly provided in this Act; or (3) prohibit or restrict the development, training, or licensing of an artificial intelligence model beyond the requirements expressly provided in this Act.

Savings clause. Clarifies the Act does not limit or supersede other federal/state privacy or security obligations (except to the extent inconsistent), does not require covered entities to proactively monitor every user interaction beyond the Act's express requirements, and does not prohibit or restrict the development, training, or licensing of an AI model beyond the Act's express requirements. Creates no new compliance obligation.

Sec. 13

Effective Date

This Act shall take effect on the date that is 180 days after the date of enactment of this Act.

Provides that the Act takes effect 180 days after enactment. No compliance obligation.

Minor Safety Parental consent · controls · termination workflows

4 items

MN-01.1

MN-01.3

MN-01.10

Covered entities must notify a minor user's parent or guardian without unreasonable delay when the minor expresses suicidal ideation while using a Tier II companion AI chatbot.

MN-01.7

Transparency AI identity disclosure · periodic reminders

4 items

T-01.1

Covered entities must provide each minor user a clear and conspicuous, plain-language disclosure at the beginning of an interaction that the companion AI chatbot is not human.

T-01.2

Covered entities must have a Tier I companion AI chatbot repeat the not-human disclosure to a minor user at least every 3 hours during a continuing interaction.

T-01.3

Covered entities must prohibit a Tier I companion AI chatbot from claiming to be a human or a licensed professional in any field to a minor user.

T-01.2

Safety Harmful content prevention · self-harm escalation

3 items

S-02.4

S-04.1

Data Controls Data sale restrictions · deidentification

3 items

D-01.9

D-01.6

Covered entities must not sell, share, or otherwise transfer a minor user's data to any third party without verifiable parental consent.

D-01.6

Covered entities must give minor users a simple, accessible in-product mechanism to delete their conversation history, with clear instructions and confirmation of deletion within a reasonable time.

Healthcare Clinical AI · provider oversight

2 items

HC-02.3

Covered entities must prohibit a minor from using a Tier III (mental-health/therapeutic) companion AI chatbot unless the use is supervised by a licensed medical or mental health professional.

HC-02.2