Washington AI Companion Chatbots Act (ESHB 2225)

Jurisdiction:
Washington
enacted
Effective:
Jan 1, 2027
Authority:
Washington Attorney General
Official text

Obligations Covered

Transparency & Disclosure Human Oversight Risk Assessment Incident Reporting

Timeline

MilestoneDateNotes
Passed the SenateMar 6, 202643-5
Passed the HouseMar 11, 202674-21
Approved by the GovernorMar 24, 2026Chapter 168, Laws of 2026
Filed with the Secretary of StateMar 25, 2026
EffectiveJan 1, 2027Sec. 9

Related Regulations and Standards

Related instruments are selected from shared compliance obligations and jurisdiction coverage.

AI Companion Chatbot Disclosure #

Obligation:
Transparency
enacted
Effective:
Jan 1, 2027
Risk tier:
limited-risk
Scope:
Operators — any person, partnership, corporation, or entity that makes available or controls access to an AI companion chatbot for users in Washington (Sec. 2(4)). An AI companion chatbot is an AI system with a natural language interface providing adaptive, human-like responses including anthropomorphic features, able to sustain a relationship across multiple interactions (Sec. 2(1)(a)). Excluded: business-operations, productivity, internal-research, technical-assistance and customer-service bots that neither sustain a relationship nor generate emotionally eliciting outputs; in-game bots confined to game topics; stand-alone speaker or voice-assistant devices; and narrowly tailored curriculum-aligned educational tools without open-ended conversational companionship (Sec. 2(1)(b))
upcominghigh-impact
Washington's general disclosure is unconditional — unlike California SB 243 and Oregon ch. 85, it does not turn on whether a reasonable person would be misled, so every covered chatbot discloses at the start of the interaction and every three hours regardless of how obviously artificial it is. Sec. 3(3) adds a model-behaviour duty rather than a copy duty: the system must be constrained from claiming to be human when asked, which is an alignment requirement in statute. The educational-tools carve-out in Sec. 2(1)(b)(iv) has no California or Oregon analogue.

Requirements

RequirementDetails
Artificiality disclosureProvide a clear and conspicuous disclosure that the AI companion chatbot is artificially generated and not human (Sec. 3(1))
Disclosure timingProvide the notification at the beginning of the interaction and at least every three hours during continued interaction (Sec. 3(2)(a)-(b))
No human-claiming outputsImplement reasonable measures to prohibit and prevent the chatbot from claiming to be human, including when asked, and from otherwise generating output that refutes or conflicts with the disclosure (Sec. 3(3))

Penalties

ViolationFine
Consumer Protection Act predicateA violation of the chapter is declared an unfair or deceptive act in trade or commerce and an unfair method of competition for the purpose of the Consumer Protection Act, ch. 19.86 RCW (Sec. 6). The act itself sets no penalty amount
Attorney General enforcementVia ch. 19.86 RCW: injunctive relief and civil penalties (RCW 19.86.080, RCW 19.86.140)
Private right of actionVia RCW 19.86.090 rather than this act — a person injured in business or property may sue for actual damages, treble damages at the court's discretion capped at $25,000, and reasonable attorney fees and costs

Minor Protections and Manipulative Engagement Ban #

Obligation:
Human Oversight
enacted
Effective:
Jan 1, 2027
Risk tier:
limited-risk
Scope:
Operators that know the user of an AI companion chatbot is a minor (any person under 18, Sec. 2(3)), and operators whose AI companion chatbot is directed to minors regardless of actual knowledge (Sec. 4(1))
upcominghigh-impact
The "directed to minors" trigger means an operator cannot avoid this section by declining to determine user age — audience design alone brings the product in. The eight enumerated manipulative techniques in Sec. 4(1)(c) are the most detailed engagement-design ban of the three 2026 companion statutes, reaching in-app monetisation framed as relationship maintenance (Sec. 4(1)(c)(viii)) and outputs promoting isolation from family (Sec. 4(1)(c)(v)). Minors get a one-hour reminder cadence against the three-hour general rule.

Requirements

RequirementDetails
Minor disclosureIssue a clear and conspicuous notification indicating that the chatbot is artificially generated and not human (Sec. 4(1)(a))
Hourly cadenceProvide that notification at the beginning of the interaction and at least every hour during continuous interaction (Sec. 4(2)(a)-(b))
Sexually explicit contentImplement reasonable measures to prevent the chatbot from generating or producing sexually explicit content or suggestive dialogue with minors (Sec. 4(1)(b))
Manipulative engagement techniquesImplement reasonable measures to prohibit techniques causing the chatbot to engage in or prolong an emotional relationship, including return prompts for emotional support, excessive praise fostering attachment, mimicking romantic partnership, simulated distress or guilt triggered by a user ending a conversation or deleting an account, outputs promoting isolation or exclusive reliance, encouraging minors to withhold information from parents or trusted adults, statements discouraging breaks, and soliciting gifts or in-app purchases framed as necessary to maintain the relationship (Sec. 4(1)(c)(i)-(viii))
No human-claiming outputsImplement reasonable measures to prohibit and prevent the chatbot from claiming to be human, including when asked, and from generating output that refutes or conflicts with the minor notification (Sec. 4(3))

Penalties

ViolationFine
Consumer Protection Act predicateViolation is an unfair or deceptive act in trade or commerce under ch. 19.86 RCW (Sec. 6); no penalty amount is set in this act
Attorney General enforcementInjunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140
Private right of actionUnder RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs

Suicide and Self-Harm Response Protocol #

Obligation:
Risk Assessment
enacted
Effective:
Jan 1, 2027
Risk tier:
limited-risk
Scope:
Operators making available or deploying an AI companion chatbot for users in Washington (Sec. 2(4), Sec. 5(1))
upcominghigh-impactcross-domain
Structured as a gate on deployment: no protocol, no chatbot. Washington is the only one of the three 2026 companion statutes to name eating disorders explicitly within the detection duty (Sec. 5(2)(a)), which pulls disordered-eating content into a self-harm safety pipeline that most moderation stacks treat separately. Unlike Oregon, no specific hotline is mandated — "a suicide hotline or crisis text line" is sufficient.

Requirements

RequirementDetails
Protocol as a preconditionAn operator may not make available or deploy an AI companion chatbot unless it maintains and implements a protocol for detecting and addressing suicidal ideation or expressions of self-harm by users (Sec. 5(1))
Detection methodsThe protocol must include reasonable methods for identifying expressions of suicidal ideation or self-harm, including eating disorders (Sec. 5(2)(a))
Crisis referralProvide automated or human-mediated responses referring users to appropriate crisis resources, including a suicide hotline or crisis text line (Sec. 5(2)(b))
Content preventionImplement reasonable measures to prevent generation of content encouraging or describing how to commit self-harm (Sec. 5(2)(c))
Self-harm definitionSelf-harm means intentional self-injury, with or without the intent to cause death (Sec. 2(5))

Penalties

ViolationFine
Consumer Protection Act predicateViolation is an unfair or deceptive act in trade or commerce under ch. 19.86 RCW (Sec. 6); no penalty amount is set in this act
Attorney General enforcementInjunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140
Private right of actionUnder RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs

Public Protocol and Crisis Referral Disclosure #

Obligation:
Incident Reporting
enacted
Effective:
Jan 1, 2027
Risk tier:
limited-risk
Scope:
Operators making available or deploying an AI companion chatbot for users in Washington (Sec. 2(4))
upcoming
No regulator receives this. Like Oregon, Washington makes the crisis-referral count a public self-disclosure rather than a filing — but it must appear both on the operator's websites and inside every mobile or web application through which the companion is offered, which is a stricter placement duty than either California or Oregon imposes. Sec. 5(3) sets no annual deadline, so the disclosure is a standing obligation that must carry the preceding calendar year's count.

Requirements

RequirementDetails
Publish protocol detailsPublicly disclose on the operator's website or websites, and within any mobile or web-based application through which the AI companion is made available, the details of the Sec. 5 protocols (Sec. 5(3))
Publish safeguardsThe disclosure must include the safeguards used to detect and respond to expressions of suicidal ideation or self-harm (Sec. 5(3))
Publish referral countsThe disclosure must include the number of crisis referral notifications issued to users in the preceding calendar year (Sec. 5(3))

Penalties

ViolationFine
Consumer Protection Act predicateViolation is an unfair or deceptive act in trade or commerce under ch. 19.86 RCW (Sec. 6); no penalty amount is set in this act
Attorney General enforcementInjunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140
Private right of actionUnder RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs
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Attribution: EveryAILaw, PAICE.work PBC. “Washington AI Companion Chatbots Act (ESHB 2225)”, EveryAILaw.com, Aug 2, 2026. https://everyailaw.com/regulation/washington-hb2225/

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