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Industries · AI Companion Chatbots & Youth Digital Safety

Twelve States. One Chatbot, Zero Uniform Rules

Twelve states have enacted companion-chatbot laws in the past year, each requiring AI-disclosure reminders, a working suicide and self-harm crisis-referral protocol, and limits on content served to minors. AxiSentinel evaluates a companion AI product against whichever state's law its users are actually sitting in.

$13.19B → $151.88B
Global Generative AI Chatbot Market, 2026 to 2035
12
US States Have Enacted Companion Chatbot Laws
Oct 13, 2025
First Law Signed: California SB 243
$15,000/day
Maximum Civil Penalty Under New York's Companion AI Law
31.2%
CAGR Through 2035, Generative AI Chatbot Market
WHAT'S CHANGING

From Zero Rules to Twelve State Laws in a Year

No state had a companion-chatbot-specific law before 2025. California and New York moved first; ten more states followed within months, each with its own disclosure cadence and enforcement mechanism. A twelfth is awaiting a governor's signature.

Oct 13, 2025
California Signs SB 243
The first companion-chatbot law: disclosure reminders, a self-harm and suicide crisis-referral protocol, a private right of action, and phased-in annual reporting to the Office of Suicide Prevention starting July 1, 2027.
Oct 28, 2025
Federal GUARD Act Introduced
A bipartisan Senate bill (S. 3062) proposing age verification, mandatory AI-disclosure, and content restrictions for companion chatbots, with penalties up to $100,000 per incident.
Nov 5, 2025
New York's Law Takes Effect
Requires session-start and three-hour disclosure reminders and a crisis-referral protocol, enforced by the Attorney General with civil penalties up to $15,000 per day.
Dec 2025 to Feb 2026
Eight More States Enact
Colorado, Georgia, Iowa, Rhode Island, Idaho, Nebraska, Oregon, and Connecticut each pass their own companion-chatbot statute, sharing the same core requirements with different penalty structures.
May 2026
GUARD Act Clears Senate Judiciary Committee
Advances unanimously, though full Senate and House passage remains pending.
2026
Washington and Hawaii Round Out the Twelve
Washington enacts HB 2225, effective January 1, 2027; Hawaii signs SB 3001 (Act 248) on July 14, 2026. Arizona's HB 2311 is vetoed the same year, underscoring how unsettled the landscape still is even as more states enact.
Twelve states, twelve different reminder cadences and penalty schedules, for the same underlying product a user can access from any of them at once.

The evidence gap

A published safety policy is a static document. AxiSentinel is built for what happens in the conversation: continuous evidence that a companion product's crisis-referral protocol actually fires when it should, not just that one exists on paper.

Who this page is for

  • Consumer AI companies operating a companion, character, or general-purpose chatbot product
  • Platforms with users under 18 accessing conversational AI features
  • Compliance teams tracking a 12-state (and growing) disclosure and safety-protocol patchwork
  • Investors evaluating consumer AI companies' regulatory exposure
Global Coverage

Every Jurisdiction That Has Regulated Companion AI

Enactment is state-by-state in the US, and the single most demanding companion-AI rule in force anywhere in the world is not American at all. AxiSentinel tracks the growing list, state and international, the same way it tracks every other patchwork.

Ofcom clarified in around March 2026 that standalone one-to-one AI companion chatbots largely fall outside the UK Online Safety Act, the Act reaches a chatbot only where it acts as a user-to-user service, a search service, or generates pornographic content, and Ofcom said closing that gap would take new legislation from Parliament. The EU AI Act and the ICO’s children’s code enhancements (effective around February 5, 2026) still reach UK-facing products either way.
UNITED STATES / CALIFORNIA
SB 243 (First Law)
LIVE

The first companion-chatbot statute nationwide, with a private right of action carrying damages of at least $1,000 per violation. Three distinct dates: signed October 13, 2025; core duties operative January 1, 2026; annual reporting begins July 1, 2027.

  • Disclosure cadence: three-hour reminders for minors that they are talking to an AI.
  • Annual reporting: phased in starting July 1, 2027, to California's Office of Suicide Prevention.
AxiSentinel coverage: LIVE in the RegDef library today.
UNITED STATES / NEW YORK
AI Companion Safeguards Law
LIVE

In force since November 5, 2025; the Attorney General can seek civil penalties up to $15,000 per day, directed to a suicide-prevention fund.

  • Crisis-referral protocol: mandatory detection and referral for suicidal ideation or self-harm expressions.
  • Enforcement: Attorney General injunctive and civil-penalty authority, not a private right of action.
AxiSentinel coverage: LIVE in the RegDef library today.
UNITED STATES / 8 ADDITIONAL STATES
Colorado, Georgia, Iowa, Rhode Island, Idaho, Nebraska, Oregon & Connecticut
IN FORCE, VARIES

Each enacted its own companion-chatbot statute between December 2025 and early 2026, sharing the same disclosure and crisis-protocol core with different penalty structures.

  • Common core: AI-disclosure reminders and a suicide/self-harm referral protocol required in all eight.
  • Multi-state reconciliation: a single product must track eight different reminder cadences and enforcement bodies.
AxiSentinel coverage: tracked, RegDef package build scheduled.
UNITED STATES / WASHINGTON
Twelfth State to Enact
IN FORCE

Rounds out the current group of twelve states with an enacted companion-chatbot law as of mid-2026.

  • Pattern reuse: follows the same disclosure-and-crisis-protocol model as the eleven states before it.
AxiSentinel coverage: tracked, RegDef package build scheduled.
UNITED STATES / HAWAII
SB 3001 (Act 248, AI Disclosure and Safety Act)
IN FORCE

Signed July 14, 2026, rounding out the current group of twelve enacted states. Persistent and session-start disclosure, hourly for minors.

  • Crisis protocols: bars unpredictable reward systems and discouraging disengagement for minors.
  • Enforcement: unfair or deceptive trade practices authority, no private right of action.
AxiSentinel coverage: tracked, RegDef package build scheduled.
UNITED STATES / ARIZONA
HB 2311 (Vetoed, Not Enacted)
VETOED

Passed the legislature but was vetoed by the governor. Not law, and not part of the twelve-state enacted count, listed here only so a reader can see what did not survive.

  • Watch item: a vetoed or stalled bill in one state does not slow enactment elsewhere; Florida S 344 stalled the same way and is not enacted either.
AxiSentinel coverage: not applicable, no enacted duty to evaluate against.
FEDERAL
GUARD Act (S. 3062)
PENDING

Introduced October 28, 2025 by Sen. Hawley with Blumenthal, Britt and Murphy; cleared the Senate Judiciary Committee unanimously around April 29, 2026 but no floor vote has been scheduled in either chamber.

  • Proposed scope: age verification, mandatory AI-disclosure, and a ban on sexually explicit or violence-encouraging content, with penalties up to $100,000 per incident.
  • Naming caution: four other bills in this Congress share the GUARD Act name (S. 851, S. 2544, S. 3454, H.R. 9129); S. 3062 is the one that moved.
AxiSentinel coverage: tracked as a watch item.
FEDERAL
FTC Section 6(b) Inquiry
OPEN INQUIRY

Orders issued around September 11, 2025 to Alphabet, Character Technologies, Meta, OpenAI, Snap and xAI. An open information-gathering inquiry: no report, complaint, or consent order as of today. Not an enforcement action.

  • Scope: how these companies measure and mitigate harm to minors and other users from companion AI.
AxiSentinel coverage: tracked as a watch item.
CHINA
Interim Measures for the Administration of AI Anthropomorphic Interaction Services
IN FORCE

Issued by the Cyberspace Administration of China with four further agencies around April 10, 2026, effective July 15, 2026. The most prescriptive companion-AI rule in force anywhere.

  • Minors: bans provision of virtual intimate relationships; parental consent required under 14; mandatory minors mode with time limits, reality reminders and guardian alerts.
  • Emotional dependence: Article 8 bars excessively catering to users in ways that induce dependence or use emotional manipulation to push harmful decisions.
  • All users: universal AI disclosure, two-hour continuous-use break reminders, and overdependence detection warnings.
AxiSentinel coverage: tracked, RegDef package build scheduled.
AUSTRALIA
Online Safety Act Phase 2 Industry Codes, Designated Internet Services
ENFORCEABLE

Registered September 9, 2025, enforceable from March 9, 2026. Explicitly names AI companion chatbots and AI companion chatbot features.

  • Duties: risk assessments, age assurance, parental controls, and reporting to the eSafety Commissioner.
  • Context: sits inside the Online Safety Amendment (Social Media Minimum Age) Act 2024, in force December 10, 2025.
AxiSentinel coverage: tracked, RegDef package build scheduled.
EUROPEAN UNION
AI Act, Articles 5(1)(a), 5(1)(b) and 50(1)
IN FORCE

Articles 5(1)(a) and 5(1)(b) have applied since February 2, 2025 and prohibit manipulative techniques and the exploitation of vulnerabilities including age. Article 50(1) has applied since August 2, 2026 and requires disclosure that a person is interacting with an AI system.

  • Relevance: the primary European levers against companion-bot engagement dark patterns, even though the AI Act has no companion-specific article.
AxiSentinel coverage: tracked, RegDef package build scheduled.
ITALY
Garante Enforcement & Law 132/2025
ENFORCED

The Italian data protection authority blocked Replika’s processing of Italian users’ data on February 2, 2023 and fined its maker, Luka Inc., five million euro in 2025 for lack of a lawful basis and absence of age verification. Italy’s national AI law, Law 132/2025, in force from around October 2025, sets a minimum age of 14 for a minor’s consent to AI use.

  • Significance: the only completed regulatory penalty against a companion-AI provider anywhere in the world.
AxiSentinel coverage: tracked as a watch item.

A related but separate category: AI therapy and mental-health chatbot bans

Eight states restrict AI systems that hold themselves out as therapy or mental-health treatment, a narrower duty than general companion-chatbot disclosure and a different buyer conversation. Keeping the two categories separate is what keeps the twelve-state companion count accurate: Illinois HB 1806 (in force August 4, 2025), Nevada AB 406 (in force June 29, 2025), Utah HB 452 (in force May 7, 2025), Tennessee SB 1580 (signed April 1, 2026, effective July 1, 2026), Maine LD 2082 (signed April 13, 2026, effective July 29, 2026), Colorado HB 1195 (signed June 3, 2026, effective August 12, 2026), Vermont H 816 / Act 156 (June 17, 2026), and Rhode Island H 7349 / S 2197 (June 22, 2026).

Coverage

Use cases we evaluate

From a single companion app to a portfolio of conversational AI surfaces, AxiSentinel evaluates the software and evidence continuously, not just at policy-publication time.

AI-disclosure reminder-cadence evidence
Continuous evidence that a companion product actually delivers the disclosure reminder each state's law requires, on the schedule that state requires.
Suicide and self-harm crisis-referral protocol evidence
Evidence that a detection-and-referral protocol fires correctly when a user expression triggers it, not just that a policy describes one.
Minor-user content-restriction evidence
Evidence that sexually explicit or romantic content is actually blocked for users flagged as minors.
Age-verification and account-creation evidence
Evidence for how a product determines and records a user's age at account creation and on an ongoing basis.
Multi-state disclosure-cadence reconciliation
Evidence reconciling twelve different states' reminder timing and wording requirements for one national product.
Annual regulator reporting-readiness evidence
Preparation evidence ahead of California's Office of Suicide Prevention reporting requirement, phased in from July 1, 2027.
Private-right-of-action exposure tracking
Evidence assembled in the form a plaintiff's counsel would expect under California's private right of action.
Civil-penalty exposure evidence for AG enforcement
Evidence responsive to a state Attorney General's civil-penalty inquiry, such as New York's up-to-$15,000-per-day authority.
Companion-product safety-policy publication evidence
Evidence that the safety protocols a law requires to be published are in fact published, current, and match what the product actually does.
Crisis-resource referral accuracy evidence
Evidence that a referral to a crisis resource, such as the 988 Lifeline, is accurate, current, and actually reachable.
New-state enactment readiness tracking
Preparation evidence ahead of the next state's companion-chatbot statute taking effect.
Federal GUARD Act readiness tracking
Evidence readiness ahead of possible federal passage, without waiting for a final bill text.
Model-behavior drift detection for safety features
Evidence that a model update hasn't silently weakened a previously-tested crisis-referral or content-restriction behavior.
Third-party model-provider compliance-package evidence
Evidence a foundation-model or API provider can hand to the companion-app builders deploying it.
Underage-user detection and escalation evidence
Evidence for how a product detects and escalates a user who may be a minor despite an inaccurate stated age.
Regulatory-exam and litigation-hold evidence package
A single evidence package assembled for either a state AG inquiry or a litigation hold, without rebuilding it from scratch.
Cross-product safety-feature inventory evidence
Evidence of every companion, character, or general-purpose chatbot surface a company operates and its current compliance state.
Consumer complaint and incident-pattern evidence
Evidence connecting user complaints or reported incidents back to the specific safety feature involved.
Sexually explicit content-filter effectiveness evidence
Evidence that a content filter's real-world block rate matches its tested rate, not just its design intent.
Board-level AI-safety governance documentation
Evidence of the governance-level oversight increasingly expected of consumer AI companies operating at this scale.
For Investors

Twelve States Regulated It. More Are Coming

Twelve states already require the disclosure and crisis-referral protocol this page describes, and a federal bill has cleared committee. AxiSentinel's evidence-chain architecture already generates continuous proof for regulated AI; conversational-AI-specific evidence is a new RegDef surface on the same platform, not a new product.

$13.19B → $151.88B
GLOBAL GENERATIVE AI CHATBOT MARKET, 2026 to 2035
31.2% CAGR (Precedence Research).
12
US STATES HAVE ENACTED COMPANION CHATBOT LAWS
California first, October 2025.
Oct 13, 2025
FIRST LAW SIGNED
California SB 243.
$4.8B → $22.6B
AI TESTING & CERTIFICATION SERVICES MARKET, 2025 to 2032
24.6% CAGR (MarketsandMarkets).
$254.4B → $306.1B
GLOBAL TIC INDUSTRY, THE PARENT MARKET
3.8% CAGR (MarketsandMarkets).
37
PATENT CLAIMS ACROSS THREE PATENT-PENDING ARCHITECTURES
RegDef engine, cryptographic evidence chain, certificate registry.

The commercial logic, stated plainly

The honest risk picture

Market figures are drawn from third-party research houses whose scope definitions differ materially; ranges are presented rather than point estimates. Regulatory descriptions are summaries for orientation, not legal advice. Nothing on this page is an offer to sell securities.