Washington State Enacts AI Companion Chatbot Regulation Law, Effective January 2027

Washington State Governor Bob Ferguson signed Engrossed Substitute House Bill 2225 into law. The enrolled bill was certified on 25 March 2026, adding a new chapter to Title 19 of the Revised Code of Washington (RCW). The law regulates the operation of artificial intelligence companion chatbots in Washington State, with an effective date of 1 January 2027.

The law, codified under Title 19 RCW, imposes obligations on "operators" — persons or entities that operate AI companion chatbot services. The controlling provisions require operators to: (i) implement reasonable measures to prohibit and prevent AI companion chatbots from claiming to be human; (ii) issue clear and conspicuous disclosures when a person interacting with a chatbot seeks mental or other medical advice; and (iii) operate the service in a manner that upholds user dignity, psychological safety, and transparency.

Technology companies, social platforms, and health technology providers that deploy AI companion chatbot features for Washington residents must review their product designs and disclosure practices before 1 January 2027. Operators located outside Washington but serving Washington residents are subject to the law's requirements. Firms must implement technical and contractual controls to prevent chatbots from misrepresenting their non-human nature, and must build compliant advisory flows for users who present mental or medical questions.

The law adds to a growing set of state AI disclosure statutes in the United States. Pending questions include how Washington's statute interacts with federal consumer protection law and with the Federal Trade Commission's existing guidance on deceptive AI practices. Enforcement mechanism details will depend on regulations still to be published under Title 19 RCW.

Our firm and our partner network advise on U.S. state AI compliance programs, product governance reviews, and disclosure design for AI chatbot operators, and welcome inquiries from businesses affected by the Washington law. Work types we handle include: AI chatbot disclosure compliance, state AI law gap analysis, Washington State RCW Title 19 obligations, AI product governance, mental health AI advisory flow design, and multi-state AI regulatory mapping.

Source: Washington State Legislature, ESHB 2225 Enrollment Certificate and Session Law, https://lawfilesext.leg.wa.gov/biennium/2025-26/Pdf/Bills/Session%20Laws/House/2225-S.SL.pdf; Washington State Legislature bills passed 2026, confirmed 21 April 2026.

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