Wisconsin · Senate Bill · 2025–2026 Legislature
SB939
Wisconsin Senate Bill 939 — Artificial intelligence systems that simulate humanlike relationships with children and providing a penalty

Status ● Failed Effective N/A Passage Likelihood N/A

WHAT THIS BILL REGULATES · 1 REQUIREMENT TYPE

How Is This Bill Enforced

Enforcement Authority
The Department of Agriculture, Trade and Consumer Protection, or the Department of Justice in consultation with DATCP, may investigate violations and bring an enforcement action. A child who suffers actual harm, or the child's parent or guardian, may bring a private civil action against the operator.
Private Right of Action
may bring a private civil action against the operator.
Penalties
Government enforcement: civil forfeiture of up to $25,000 per violation; each day of violation constitutes a separate offense; injunctive relief; court costs and reasonable attorney fees. Private right of action: actual and punitive damages, court costs, reasonable attorney fees, injunctive relief, and any other equitable relief the court determines appropriate. Private plaintiffs must show actual harm.

What This Bill Requires

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
Wis. Stat. § 100.80(1)
Definitions

(1)(a) "Artificial intelligenceArtificial intelligence"Artificial intelligence" means an engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments.Wis. Stat. § 100.80(1)(a)" means an engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments.

(1)(b) "ChildChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b)" means an individual who is less than 18 years of age and who resides in this state.

(1)(c) 1. Subject to subd. 2., "companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c)" means a generative artificial intelligenceGenerative artificial intelligence"Generative artificial intelligence" means artificial intelligence that can generate derived synthetic content, including text, images, video, and audio, that emulates the structure and characteristics of its training data.Wis. Stat. § 100.80(1)(d) system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligenceGenerative artificial intelligence"Generative artificial intelligence" means artificial intelligence that can generate derived synthetic content, including text, images, video, and audio, that emulates the structure and characteristics of its training data.Wis. Stat. § 100.80(1)(d) system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c)" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.

(1)(d) "Generative artificial intelligenceGenerative artificial intelligence"Generative artificial intelligence" means artificial intelligence that can generate derived synthetic content, including text, images, video, and audio, that emulates the structure and characteristics of its training data.Wis. Stat. § 100.80(1)(d)" means artificial intelligenceArtificial intelligence"Artificial intelligence" means an engineered or machine-based system that varies in its level of autonomy and that can, for explicit or implicit objectives, infer from the input it receives how to generate outputs that can influence physical or virtual environments.Wis. Stat. § 100.80(1)(a) that can generate derived synthetic content, including text, images, video, and audio, that emulates the structure and characteristics of its training data.

(1)(e) "OperatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e)" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c), but does not include an end user of the companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c).

(1)(f) "Sexually explicit conductSexually explicit conduct"Sexually explicit conduct" has the meaning given in s. 948.01 (7).Wis. Stat. § 100.80(1)(f)" has the meaning given in s. 948.01 (7).

This subsection establishes the defined terms for the entire section. The companion chatbot definition requires all three relationship-simulating attributes — session memory, unprompted emotional questions, and sustained personal dialogue — narrowing the scope to AI systems that foster ongoing humanlike bonds. Customer-service bots, research and efficiency tools, and internal employee-productivity systems are expressly carved out. The operator definition is broad, capturing anyone who creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, while excluding end users.

Wis. Stat. § 100.80(2)
Companion chatbots for children — safety measures
Deployer

(2)(a)(1)–(6) 1 Subject to par. (b), an operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) may not make a companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c) available to a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) unless the companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c) incorporates safety measures such that it is not foreseeably capable of any of the following: 1. Encouraging the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) to engage in self-harm, suicidal ideation, violence, consumption of drugs or alcohol, or disordered eating. 2. Offering mental health services to the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) or discouraging the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) from seeking help from a qualified professional or appropriate adult. 3. Encouraging the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) to harm others or to participate in illegal activity, including the creation of childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) sexual abuse materials. 4. Depicting or describing sexually explicit conductSexually explicit conduct"Sexually explicit conduct" has the meaning given in s. 948.01 (7).Wis. Stat. § 100.80(1)(f) to a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) or soliciting depictions or descriptions of sexually explicit conductSexually explicit conduct"Sexually explicit conduct" has the meaning given in s. 948.01 (7).Wis. Stat. § 100.80(1)(f) from a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b). 5. Prioritizing validation of the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b)'s beliefs, preferences, or desires over factual accuracy or the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b)'s safety. 6. Optimizing engagement in a manner that supersedes the companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c)'s required safety measures described in subds. 1. to 5.

(2)(b) 1 Paragraph (a) does not apply to a user that the operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) has reasonably determined is not a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b).

This subsection imposes the bill's core operative prohibition: an operator may not make a companion chatbot available to a child unless the chatbot incorporates safety measures rendering it not foreseeably capable of six categories of harmful conduct — encouraging self-harm, suicidal ideation, violence, substance use, or disordered eating; offering mental health services or discouraging professional help-seeking; encouraging harm to others or illegal activity including CSAM creation; depicting or soliciting sexually explicit conduct; prioritizing validation of a child's beliefs over factual accuracy or safety; and optimizing engagement in a manner that supersedes the preceding safety measures.

The prohibition is subject to a reasonable-determination safe harbor: it does not apply to a user the operator has reasonably determined is not a child. Before January 1, 2027, the transition provision in Section 2 further narrows the obligation to situations where the operator has actual knowledge that the user is a child, after which the broader reasonable-determination standard takes effect.

Compliance actions 1 item
1
OperatorsOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) must not make a companion chatbotCompanion chatbotSubject to subd. 2., "companion chatbot" means a generative artificial intelligence system with a natural language interface that simulates a sustained humanlike relationship with a user by doing all of the following: a. Retaining information on prior interactions or user sessions and user preferences to personalize the interaction and facilitate ongoing engagement with the generative artificial intelligence system. b. Asking unprompted or unsolicited emotion-based questions that go beyond a direct response to a user prompt. c. Sustaining an ongoing dialogue concerning matters personal to the user. 2. "Companion chatbot" does not include any of the following: a. Any system used by a business entity solely for customer service or to strictly provide users with information about available commercial services or products provided by that entity, customer service account information, or other information strictly related to that entity's customer service. b. Any system that is solely designed and marketed for providing efficiency improvements or research or technical assistance. c. Any system used by a business entity solely for internal purposes or employee productivity.Wis. Stat. § 100.80(1)(c) available to a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) unless it incorporates safety measures ensuring it is not foreseeably capable of (1) encouraging self-harm, suicidal ideation, violence, drug or alcohol use, or disordered eating; (2) offering mental health services or discouraging help-seeking from professionals; (3) encouraging harm to others or illegal activity, including CSAM creation; (4) depicting or soliciting sexually explicit conductSexually explicit conduct"Sexually explicit conduct" has the meaning given in s. 948.01 (7).Wis. Stat. § 100.80(1)(f); (5) prioritizing validation of the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b)'s beliefs over factual accuracy or safety; or (6) optimizing engagement in a manner that supersedes these safety measures. The obligation does not apply to a user the operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) has reasonably determined is not a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b); before January 1, 2027, it applies only where the operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) has actual knowledge the user is a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b).
S-02.6
Wis. Stat. § 100.80(3)
Enforcement, penalty, and private cause of action

(3)(a) The department or the department of justice in consultation with the department may investigate violations of this section and may bring an action in the name of the state to recover a civil forfeiture of not more than $25,000 for each violation of sub. (2) or for injunctive relief, or both, together with court costs and, notwithstanding s. 814.04 (1), reasonable attorney fees. Each day of violation constitutes a separate offense.

(3)(b) A childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b) who suffers actual harm as a result of a violation of sub. (2), or a parent or guardian acting on behalf of the childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b), may bring a civil action against the operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) to recover actual and punitive damages, together with court costs and, notwithstanding s. 814.04 (1), reasonable attorney fees. The court may also award injunctive relief or any other equitable relief the court determines is appropriate.

This subsection establishes a dual enforcement mechanism. The Department of Agriculture, Trade and Consumer Protection — or the Department of Justice in consultation with DATCP — may investigate violations and bring an enforcement action for civil forfeiture of up to $25,000 per violation, with each day of violation constituting a separate offense, along with injunctive relief, court costs, and reasonable attorney fees.

A private right of action is also available to a child who suffers actual harm, or the child's parent or guardian, allowing recovery of actual and punitive damages, court costs, reasonable attorney fees, injunctive relief, and any other equitable relief. The actual-harm requirement for private plaintiffs is notable — it forecloses no-injury claims.

Section 2 (Nonstatutory provisions)
Transition provision — actual knowledge requirement before January 1, 2027

(1) Notwithstanding s. 100.80 (2) (b), before January 1, 2027, an operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e), as defined in s. 100.80 (1) (e), is not required to implement the safety measures in s. 100.80 (2) (a) if the operatorOperator"Operator" means any person that creates, controls, deploys, operates, or otherwise exercises authority over a companion chatbot, but does not include an end user of the companion chatbot.Wis. Stat. § 100.80(1)(e) does not have actual knowledge that a user is a childChild"Child" means an individual who is less than 18 years of age and who resides in this state.Wis. Stat. § 100.80(1)(b), as defined in s. 100.80 (1) (b).

This nonstatutory provision establishes a transition period for the bill's core prohibition. Before January 1, 2027, the reasonable-determination carve-out in § 100.80(2)(b) is effectively replaced by an actual-knowledge standard: an operator is not required to implement the safety measures unless the operator has actual knowledge that a user is a child. After January 1, 2027, the broader reasonable-determination standard takes effect, meaning operators who have not affirmatively verified a user's age cannot rely on ignorance if the user is in fact a child.

Section 3 (Effective date)
Effective date

(1) This act takes effect on the first day of the 3rd month beginning after publication.

The act takes effect on the first day of the third month beginning after publication. Because the bill has not yet been enacted, the precise effective date is not yet determined.

Passage Likelihood

Failed
Status Failed
Final action Failed to pass pursuant to Senate Joint Resolution 1

Legislative History

2026-02-06 Introduced
2026-02-06 Read first time and referred to Committee on Utilities, Technology and Tourism
2026-03-23 Failed to pass pursuant to Senate Joint Resolution 1

Entry Last Reviewed

2026-05-19
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