US State AI Chatbot Laws in 2026: What Compliance Teams Need to Know

This blog was originally posted on 21st October, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY Samantha Anguiano, Regulatory Compliance Specialist, Adherent

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Key Insight

Nine states passed 10 AI chatbot laws in 2026, and most of their obligations take effect between mid-2026 and mid-2027. The laws differ mainly in which chatbots they cover, but their core duties are similar: disclose that users are talking to AI and protect minors. With no federal chatbot statute, companies that offer chatbots nationwide must follow a growing patchwork of state rules and check applicability state by state.

Table of Contents

• Key takeaways
• What counts as a chatbot?
• Who has to comply?
• What is excluded?
• Core obligations
• Key laws: effective dates and penalties
• AI Chatbot Compliance Checklist for 2026–2027
• Looking ahead: what’s next at the federal level
• Frequently Asked Questions

AI chatbots were the fastest-moving area of state AI legislation in 2026. Nine states passed 10 chatbot laws, and most of their obligations take effect between mid-2026 and mid-2027. Congress has not passed a federal chatbot statute, so companies that offer chatbots nationwide must now follow a growing patchwork of state rules.

Key takeaways

• 9 states, 10 laws. California, Colorado, Connecticut, Georgia, Hawaii, Idaho, Iowa, Nebraska, and Washington now regulate AI chatbots.
• Definitions decide everything. Some states regulate only companion chatbots, others reach almost any public-facing conversational AI.
• The core duties are similar. Disclose that users are talking to AI and protect minors.
• Deadlines are close. Two laws already apply, four more take effect on January 1, 2027, and the last four on July 1, 2027.

What counts as a chatbot?

In general terms, a chatbot is software that uses AI to hold a conversation with a person through text or voice, responding in a way that imitates human dialogue. That covers a wide range of products, from customer service assistants and shopping helpers to general-purpose assistants and apps built for companionship.

The laws, however, do not regulate every chatbot. Each state decides which chatbots it covers, and they fall into two groups:

• Some states regulate only companion chatbots (California, Connecticut, Georgia, Hawaii, Washington). These are chatbots designed to act like a friend or partner: they remember past conversations, build a personal relationship with the user and can create emotional attachment. Apps like Replika or Character.AI are typical examples. A bank’s help-desk bot would not count. California SB 867 applies the same rules to toys that include this kind of chatbot.
• Other states regulate almost any public chatbot (Colorado, Idaho, Iowa, Nebraska). They cover almost any chatbot open to the public that converses like a person, whether or not it tries to build a relationship. A general-purpose assistant can fall under these laws. Most of them add extra duties when the user is a minor with an account.

In practice, this means the same product can be regulated in one state and not in the next. A companion app is likely covered almost everywhere, while a general-purpose assistant may be covered in Colorado or Iowa but not in California.

Who has to comply?

Most of these laws place their obligations on the operator: the company that offers the chatbot to people in the state. In most states, that means the company that builds the chatbot or makes it available to users, for example through its own app or website. A company that runs a companion app for users in California is an operator there, even if it is based in another state.

A few points help draw the line:

• Washington casts the widest net. Its definition reaches “any person, partnership, corporation, or entity” that makes the chatbot available or controls it.
• App stores and search engines are usually not operators. In Hawaii, Idaho, Iowa and Nebraska, simply giving people access to someone else’s chatbot does not make a company responsible for it.
• California SB 867 reaches further down the chain. The toy ban applies to anyone who manufactures, sells or distributes a toy with a companion chatbot, not just the company behind the chatbot.

What is excluded?

It is important to keep in mind that not every chatbot is covered. States carve out low-risk bots, usually tools that help with a specific task instead of holding open-ended conversations. The most common exclusions are:

• Customer service, commerce and transactional bots.
• Bots used only for internal business, productivity, research or technical assistance. 
• Tools built mainly for developers or researchers.
• Video game characters limited to game-related replies.
• Voice assistants that do not sustain a relationship across interactions.
• Chatbot features inside another app, such as a social media platform, that are not designed for emotional companionship.
• App stores and search engines that only provide access to a chatbot. 

Most of these carve-outs come from Colorado and California. Idaho, Iowa and Nebraska exclude little beyond app stores and search engines, so a chatbot that falls outside Colorado’s law may still be a “conversational AI service” in Iowa or Nebraska. Check applicability state by state.

Core obligations

Nearly every law requires the operator to make clear that the user is talking to AI. Beyond that, the duties fall into three groups:

• AI disclosure. Georgia, Washington, Iowa and Nebraska require a “clear and conspicuous” disclosure, and Iowa and Nebraska direct it specifically to minor account holders. Hawaii and Idaho trigger the duty when a reasonable person could be misled into thinking they are talking to a human.
• Protections for minors. Colorado requires “commercially reasonable methods” to protect minor account holders and minor users. California SB 1119 bars operators from showing children cross-context behavioral advertising. Most conversational AI laws build their obligations around a minor account holder.
• Product restrictions. California SB 867 goes furthest: it bans manufacturing, selling or distributing toys with companion chatbots through January 1, 2031.

Key laws: effective dates and penalties

State	Law	Effective date	Penalty
Hawaii	SB 3001	Jul 14, 2026	Greater of actual damages or $1,000 per violation; capped at $1,000,000 per operator
Colorado	HB 1263	Aug 12, 2026	No penalty in the signed act; its rules sit in the Colorado Consumer Protection Act, whose existing enforcement may apply
California	SB 867	Jan 1, 2027	Greater of actual damages or $1,000 per violation, plus attorney’s fees (private lawsuits)
California	SB 1119	Jan 1, 2027	Up to $5,000 per affected child (negligent); up to $15,000 per affected child (intentional)
Connecticut	SB 5	Jan 1, 2027	Up to $5,000 per willful violation (Connecticut Unfair Trade Practices Act)
Washington	HB 2225	Jan 1, 2027	Up to $7,500 per violation (Consumer Protection Act); private lawsuits allowed
Georgia	SB 540	Jul 1, 2027	Up to $10,000 per knowing violation, plus damages and fees
Idaho	SB 1297	Jul 1, 2027	Greater of actual damages or $1,000 per violation; capped at $500,000 per operator
Iowa	SF 2417	Jul 1, 2027	Greater of actual damages or $1,000 per violation; capped at $500,000 per operator
Nebraska	LB 525	Jul 1, 2027	At least $1,000 per violation; capped at $500,000 per operator

AI Chatbot Compliance Checklist for 2026–2027

With several effective dates already passed and more coming in 2027, a state-by-state checklist review belongs on this quarter’s plan. 

• Map products to definitions. For each chatbot, decide whether it is a companion chatbot, a conversational AI service, or excluded in each state.
• Build one disclosure standard. Design an AI disclosure that meets the strictest “clear and conspicuous” test, then adjust it for minors.
• Settle how you identify minors. Account-holder-based laws depend on knowing who is a minor. Document your age assurance method and why it is commercially reasonable.
• Review ads and data uses involving children, especially cross-context behavioral advertising in California.
• Check hardware and toys. Any consumer product that embeds a companion chatbot needs a separate review under California SB 867.

Looking ahead: what’s next at the federal level

The next big question is whether Congress will step in. At least ten federal chatbot bills were introduced in 2026, ranging from age verification and parental consent for minors to a ban on AI chatbots in children’s toys, protections for seniors and disclosure of sponsored chatbot answers. The proposed KIDS Act, which includes chatbot rules for minors, has gone the furthest: it passed the House on June 29, 2026, but faces opposition in the Senate.

Even if the leading bills pass, they would not wipe out state chatbot laws. The KIDS Act, for instance, would override state laws only where they directly conflict, and it lets states offer greater protection to minors. The broader fight over federal preemption is happening around AI in general. The proposed FRONTIER Act, for example, would preempt some state rules for the most advanced AI models, but it expressly preserves state laws that protect minors from AI harms.

Until Congress acts, state laws are what companies must follow. The first deadlines have already passed, and the rest arrive in 2027. Compliance teams that map their chatbots against these laws now will be ready, whatever Congress decides next.

FAQ

• Which states have AI chatbot laws in 2026?
  Nine states passed 10 chatbot laws in 2026: California, Colorado, Connecticut, Georgia, Hawaii, Idaho, Iowa, Nebraska, and Washington. Congress has not passed a federal chatbot statute.
• Do these laws apply to every AI chatbot?
  No. California, Connecticut, Georgia, Hawaii, and Washington regulate only companion chatbots, while Colorado, Idaho, Iowa, and Nebraska regulate almost any public chatbot that converses like a person. States also carve out low-risk bots, such as customer service, commerce and transactional bots, so the same product can be regulated in one state and not in the next.
• Who is responsible for complying?
  Most of these laws place their obligations on the operator: the company that offers the chatbot to people in the state, even if it is based in another state. App stores and search engines are usually not operators, while Washington casts the widest net and California SB 867’s toy ban applies to anyone who manufactures, sells or distributes a toy with a companion chatbot.
• When do the state chatbot laws take effect?
  Two laws already apply: Hawaii SB 3001 (July 14, 2026) and Colorado HB 1263 (August 12, 2026). California SB 867, California SB 1119, Connecticut SB 5, and Washington HB 2225 take effect on January 1, 2027, and the Georgia, Idaho, Iowa, and Nebraska laws take effect on July 1, 2027.
• Would a federal law replace state chatbot laws?
  Not entirely. Even if the leading federal bills pass, they would not wipe out state chatbot laws. The KIDS Act, for instance, would override state laws only where they directly conflict and lets states offer greater protection to minors. Until Congress acts, state laws are what companies must follow.

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