EveryAILaw.comDoes Washington AI Companion Chatbots Act (ESHB 2225) require Human Oversight?
Washington • enacted
Yes — 1 provision
Requirements at a glance
This regulation imposes 5 specific requirements for Human Oversight across 1 provision:
- 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))
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 |