Washington AI Companion Chatbots Act (ESHB 2225)
Obligations Covered
Timeline
| Milestone | Date | Notes |
|---|---|---|
| Passed the Senate | Mar 6, 2026 | 43-5 |
| Passed the House | Mar 11, 2026 | 74-21 |
| Approved by the Governor | Mar 24, 2026 | Chapter 168, Laws of 2026 |
| Filed with the Secretary of State | Mar 25, 2026 | |
| Effective | Jan 1, 2027 | Sec. 9 |
Related Regulations and Standards
Related instruments are selected from shared compliance obligations and jurisdiction coverage.
AI Companion Chatbot Disclosure
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
| Requirement | Details |
|---|---|
| Artificiality disclosure | Provide a clear and conspicuous disclosure that the AI companion chatbot is artificially generated and not human (Sec. 3(1)) |
| Disclosure timing | Provide 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 outputs | Implement 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
| Violation | Fine |
|---|---|
| Consumer Protection Act predicate | A 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 enforcement | Via ch. 19.86 RCW: injunctive relief and civil penalties (RCW 19.86.080, RCW 19.86.140) |
| Private right of action | Via 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
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
| Requirement | Details |
|---|---|
| Minor disclosure | Issue a clear and conspicuous notification indicating that the chatbot is artificially generated and not human (Sec. 4(1)(a)) |
| Hourly cadence | Provide that notification at the beginning of the interaction and at least every hour during continuous interaction (Sec. 4(2)(a)-(b)) |
| Sexually explicit content | Implement reasonable measures to prevent the chatbot from generating or producing sexually explicit content or suggestive dialogue with minors (Sec. 4(1)(b)) |
| Manipulative engagement techniques | Implement 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 outputs | Implement 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
| Violation | Fine |
|---|---|
| Consumer Protection Act predicate | Violation 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 enforcement | Injunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140 |
| Private right of action | Under RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs |
Suicide and Self-Harm Response Protocol
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
| Requirement | Details |
|---|---|
| Protocol as a precondition | An 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 methods | The protocol must include reasonable methods for identifying expressions of suicidal ideation or self-harm, including eating disorders (Sec. 5(2)(a)) |
| Crisis referral | Provide automated or human-mediated responses referring users to appropriate crisis resources, including a suicide hotline or crisis text line (Sec. 5(2)(b)) |
| Content prevention | Implement reasonable measures to prevent generation of content encouraging or describing how to commit self-harm (Sec. 5(2)(c)) |
| Self-harm definition | Self-harm means intentional self-injury, with or without the intent to cause death (Sec. 2(5)) |
Penalties
| Violation | Fine |
|---|---|
| Consumer Protection Act predicate | Violation 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 enforcement | Injunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140 |
| Private right of action | Under RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs |
Public Protocol and Crisis Referral Disclosure
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
| Requirement | Details |
|---|---|
| Publish protocol details | Publicly 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 safeguards | The disclosure must include the safeguards used to detect and respond to expressions of suicidal ideation or self-harm (Sec. 5(3)) |
| Publish referral counts | The disclosure must include the number of crisis referral notifications issued to users in the preceding calendar year (Sec. 5(3)) |
Penalties
| Violation | Fine |
|---|---|
| Consumer Protection Act predicate | Violation 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 enforcement | Injunctive relief and civil penalties under RCW 19.86.080 and RCW 19.86.140 |
| Private right of action | Under RCW 19.86.090 — actual damages, discretionary trebling capped at $25,000, plus attorney fees and costs |
Cite this regulation
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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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