Does Oregon Artificial Intelligence Companion Act (SB 1546) require Human Oversight?
Oregon • enacted
Yes — 1 provision
Requirements at a glance
This regulation imposes 5 specific requirements for Human Oversight across 1 provision:
- Anti-anthropomorphism measures — Undertake reasonable measures to prevent the companion from generating statements that would lead a reasonable person to believe they are interacting with another natural person, including statements that explicitly claim sentience or humanity, simulate emotional dependence on the user, simulate romantic interest or sexual innuendo, or role-play romantic relationships between adults and minors (§ 1(4)(a)(A)-(D))
- Sexually explicit content — Use reasonable measures to ensure the companion or platform does not produce visual representations of sexually explicit conduct as defined in ORS 163.665, or suggest or state that the minor should engage in sexually explicit conduct (§ 1(4)(b)(C))
- No engagement-maximising rewards — Undertake reasonable measures to prevent delivery, on a variable schedule or otherwise, of a system of rewards or affirmations intended to reinforce behavior or maximise the user's engagement time (§ 1(4)(c)(A))
- No guilt-based retention — Prevent the companion from generating, in response to a user's indication of a desire to end a conversation, reduce engagement time, or delete their account, unsolicited messages of simulated emotional distress, loneliness, or abandonment, or otherwise attempting to arouse guilt or sympathy (§ 1(4)(c)(B))
- No material misrepresentation — Prevent material misrepresentation about the companion's identity, capabilities, or training data, or about whether the user is interacting with artificially generated output, including when the user directly asks (§ 1(4)(c)(C))
Minor Protection and Engagement-Maximisation Limits #
This is the provision with no California analogue. Section 1(4)(c) bans variable-ratio reward schedules, guilt-inducing exit friction, and misrepresentation of the system's identity, capabilities, or training data — engagement-optimisation patterns, regulated as product design rather than as speech. Operators serving mixed-age audiences will need an age signal to know which regime applies, though the act imposes no age-verification duty.
Requirements
| Requirement | Details |
|---|---|
| Anti-anthropomorphism measures | Undertake reasonable measures to prevent the companion from generating statements that would lead a reasonable person to believe they are interacting with another natural person, including statements that explicitly claim sentience or humanity, simulate emotional dependence on the user, simulate romantic interest or sexual innuendo, or role-play romantic relationships between adults and minors (§ 1(4)(a)(A)-(D)) |
| Sexually explicit content | Use reasonable measures to ensure the companion or platform does not produce visual representations of sexually explicit conduct as defined in ORS 163.665, or suggest or state that the minor should engage in sexually explicit conduct (§ 1(4)(b)(C)) |
| No engagement-maximising rewards | Undertake reasonable measures to prevent delivery, on a variable schedule or otherwise, of a system of rewards or affirmations intended to reinforce behavior or maximise the user's engagement time (§ 1(4)(c)(A)) |
| No guilt-based retention | Prevent the companion from generating, in response to a user's indication of a desire to end a conversation, reduce engagement time, or delete their account, unsolicited messages of simulated emotional distress, loneliness, or abandonment, or otherwise attempting to arouse guilt or sympathy (§ 1(4)(c)(B)) |
| No material misrepresentation | Prevent material misrepresentation about the companion's identity, capabilities, or training data, or about whether the user is interacting with artificially generated output, including when the user directly asks (§ 1(4)(c)(C)) |
Penalties
| Violation | Fine |
|---|---|
| Private right of action | The greater of actual damages or $1,000 statutory damages per violation, plus injunctive relief and discretionary attorney fees and costs (§ 2) |