Does Washington AI Companion Chatbots Act (ESHB 2225) require Transparency & Disclosure?

Washington • enacted

Yes — 1 provision

Requirements at a glance

This regulation imposes 3 specific requirements for Transparency & Disclosure across 1 provision:

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
View full regulation View obligation Obligation matrix