California SB 243: Companion Chatbots
CA-SB-243 · US
In force since 2026-01-01. A Binding regulation from US. SB 243 ('Companion chatbots'), Chapter 677, Statutes of 2025, approved by the Governor and filed with the Secretary of State on October 13, 2025, adds Chapter 22.6 (§§ 22601–22606) to Division 8 of the California Business and Professions Code — the first US state statute to specifically regulate 'companion chatbots' (AI systems with a natural-language interface that provide adaptive, human-like responses meeting a user's social needs). Operators must give a clear, conspicuous notification that the chatbot is AI and not human where a reasonable person would be misled (§ 22602(a)), maintain a published self-harm/crisis-referral protocol (§ 22602(b)), and protect known minors (§ 22602(c): a default every-three-hours AI/break reminder and measures against sexually explicit content). Enforcement is a private right of action (§ 22605: injunctive relief, the greater of actual damages or $1,000 per violation, and attorney's fees) — a deployment/consumer-protection design distinct from the frontier-developer transparency statute SB 53 (TFAIA, ch. 138). Operator duties are operative Jan. 1, 2026; § 22603 annual reporting to the Office of Suicide Prevention begins July 1, 2027.
Source appraisal — 48 sources across 3 types
| Source type | Authority | Count |
|---|---|---|
| Peer-reviewed✦ 32 AI | Primary / peer-reviewed | 33 |
| Preprint✦ 1 AI | Institutional | 14 |
| Civil society✦ 1 AI | Contextual | 1 |
Authority is an editorial classification by source type — not a quality score for any individual work, and not external peer review. ✦ AI-generated summaries are labelled, never dropped.
Review methods
- Review question
- How does California SB 243: Companion Chatbots govern AI across the tracked governance topics, and what cited evidence supports each classification?
- Review model
- Living evidence mapping (scoping-review idiom) — continuously updated and source-grounded. Not a registered systematic review and not externally peer-reviewed.
- Source base
- Primary legal/regulatory and standards sources; peer-reviewed and preprint academic literature (via DOI/arXiv); institutional and civil-society reports. Source types are classified in the source-appraisal table on this page.
- Inclusion
- A claim is included only when it traces to a cited primary or published source; coverage classifications are anchored to a named provision or document.
- Exclusion
- Unsourced assertions, broken or unverifiable links, and sources that do not support the claim they are attached to are excluded.
- Appraisal
- Sources are classified by source-type authority (see the source-appraisal table) — structured editorial self-classification, not external peer review.
- Synthesis
- Descriptive mapping of the instrument's coverage across topics, plus its cited literature base.
- Limitations
- English-language and editorial-capacity coverage asymmetries; reliance on official sources for legal status; some prose tiers are AI-authored and AI-reviewed without human review (labelled as such). This is not peer-reviewed scholarship.
Coverage at a glance
Coverage fingerprint — color = verdict, height = confidence. One tick per tracked topic.
Scope and obligations
SB 243 ('Companion chatbots'), Chapter 677, Statutes of 2025, approved by the Governor and filed with the Secretary of State on October 13, 2025, adds Chapter 22.6 (§§ 22601–22606) to Division 8 of the California Business and Professions Code — the first US state statute to specifically regulate 'companion chatbots' (AI systems with a natural-language interface that provide adaptive, human-like responses meeting a user's social needs). Operators must give a clear, conspicuous notification that the chatbot is AI and not human where a reasonable person would be misled (§ 22602(a)), maintain a published self-harm/crisis-referral protocol (§ 22602(b)), and protect known minors (§ 22602(c): a default every-three-hours AI/break reminder and measures against sexually explicit content). Enforcement is a private right of action (§ 22605: injunctive relief, the greater of actual damages or $1,000 per violation, and attorney's fees) — a deployment/consumer-protection design distinct from the frontier-developer transparency statute SB 53 (TFAIA, ch. 138). Operator duties are operative Jan. 1, 2026; § 22603 annual reporting to the Office of Suicide Prevention begins July 1, 2027.
California SB 243: Companion Chatbots addresses 2 contested AI-governance topics explicitly, 1 via general principles,.
Topics governed
- implicitAI in Healthcare— Cal. Bus. & Prof. Code § 22602(b) (added by SB 243) — operator must maintain a protocol preventing production of suicidal-ideation/self-harm content and referring the user to crisis-service providers, published on its website; § 22603 reports referral data to the Office of Suicide Prevention
Art. 22602(b)paraphrasean operator must maintain a protocol for preventing the production of suicidal ideation, suicide, or self-harm content, including providing a notification that refers the user to crisis service providers when the user expresses such ideation
- governsTransparency Obligations— Cal. Bus. & Prof. Code § 22602(a) (added by SB 243) — operator must issue a clear-and-conspicuous notification that the companion chatbot is artificially generated and not human where a reasonable person would be misled; § 22602(c) adds, for known minors, a default every-three-hours AI-reminder + break notification
Art. 22602(a)“If a reasonable person interacting with a companion chatbot would be misled to believe that the person is interacting with a human, an operator shall issue a clear and conspicuous notification indicating that the companion chatbot is artificially generated and not human.”
- governsIndividual Redress— Cal. Bus. & Prof. Code § 22605 (added by SB 243) — private right of action: a person injured in fact by a violation may sue for injunctive relief, the greater of actual damages or $1,000 per violation, and attorney's fees and costs
Art. 22605“A person who suffers injury in fact as a result of a violation of this chapter may bring a civil action to recover all of the following relief: (a) Injunctive relief. (b) Damages in an amount equal to the greater of actual damages or one thousand dollars ($1,000) per violation. (c) Reasonable attorney's fees and costs.”
Cross-jurisdiction comparison
How peer instruments treat the topics California SB 243: Companion Chatbots governs.
| Topic | EU-AIA-2024 | US-EO-14110 | US-EO-14179 | UK-WHITEPAPER-2023 | CN-GENAI-2023 | G7-HIROSHIMA | OECD-AI-PRIN | COE-AI-CONV | UN-RES-2024 | NIST-AI-RMF | BLETCHLEY-2023 | SEOUL-2024 | NIST-AI-RMF-GENAI | CA-SB-1047 | IN-DPDP-2023 | BR-AIBILL-2024 | ASEAN-AI-GUIDE-2024 | AU-AI-STRATEGY-2024 | ANTHROPIC-RSP-2024° | OPENAI-PREPAREDNESS-2023° | DEEPMIND-FSF-2024° | META-FRONTIER-2024° | UK-US-AISI-MOU-2024 | WH-VOLUNTARY-2023 | SG-MODEL-AI-2024 | JP-METI-AI-2024 | EU-GDPR-2016 | EU-GPAI-COP-2025 | OMB-M-24-10 | GSA-AI-GUIDE-2024 | DOD-RAI-2022 | FEDRAMP-AI-2024 | DFARS-252-204 | CA-SB-53 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Transparency Obligations | governs | implicit | silent | implicit | conflicts | governs | governs | governs | implicit | governs | implicit | governs | governs | implicit | implicit | governs | governs | silent | governs | implicit | implicit | governs | implicit | governs | governs | governs | governs | governs | governs | governs | governs | governs | silent | governs |
| Individual Redress | governs | silent | silent | implicit | governs | silent | governs | governs | silent | implicit | silent | silent | implicit | implicit | governs | governs | silent | silent | silent | silent | silent | silent | silent | silent | implicit | implicit | governs | silent | governs | implicit | implicit | implicit | silent | implicit |
°= industry self-imposed voluntary framework. Comparing a voluntary code's "governs" tint with a binding regulation's "governs" tint flattens the legal-force distinction; use the instrument-page banner for the operative status of each.
How to cite this article
APA 7
Policy Window. (2025). California SB 243: Companion Chatbots [Wiki article — Instrument]. https://policywindow.org/wiki/ca-sb-243
Chicago 17
Policy Window. 2025. "California SB 243: Companion Chatbots." Wiki article (Instrument). https://policywindow.org/wiki/ca-sb-243.
BibTeX
@misc{policywindow-ca-sb-243,
title = {California SB 243: Companion Chatbots},
author = {Policy Window},
year = {2025},
howpublished = {Cal. Stats. 2025, ch. 677 (SB 243); Cal. Bus. & Prof. Code, Div. 8, ch. 22.6, §§ 22601–22606 (added by SB 243, approved by Governor Oct. 13, 2025)},
url = {https://policywindow.org/wiki/ca-sb-243},
note = {Primary source: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB243}
}Evidence base
48 academic & grey-literature sources on the topics this instrument addresses (not commentary on the instrument itself) — catalogued metadata with a primary link; one-line findings are ✦ AI-generated summaries, labeled as such (charter §7.9). Browse the full literature index.
- Current state of Food and Drug Administration-approved artificial intelligence/machine learning medical devices: pathways, transparency, and evidence gaps Peer-reviewed✦ AIDocuments that most FDA AI/ML devices clear via the 510(k) pathway with limited clinical validation and poor transparency, exposing regulatory evidence gaps.
- Identifying Algorithmic Decision Subjects' Needs for Meaningful Contestability Peer-reviewed✦ AIEmpirically elicits what decision subjects need for contestation to be 'meaningful', informing the design of effective remedies and appeal mechanisms for ADM.
- Two Means to an End Goal: Connecting Explainability and Contestability in the Regulation of Public Sector AI Preprint✦ AIInterview study with 14 regulation experts distinguishes judicial vs non-judicial and individual vs collective contestation channels for public-sector AI remedies.
- Unregulated large language models produce medical device-like output Peer-reviewed✦ AIFinds general-purpose LLMs 'readily produced device-like decision support across a range of scenarios,' implying they should fall under medical-device regulation if clinically deployed.
- A general framework for governing marketed AI/ML medical devices Peer-reviewed✦ AIProposes a post-market governance framework for AI/ML medical devices addressing performance drift and ongoing monitoring beyond initial approval.
- Global Initiative on AI for Health (GI-AI4H): strategic priorities advancing governance across the United Nations Peer-reviewed✦ AISets out the WHO/ITU Global Initiative on AI for Health's strategic priorities to harmonize international regulatory and governance standards for health AI.
- The Right to Transparency in Public Governance: Freedom of Information and the Use of Artificial Intelligence by Public Agencies Peer-reviewed✦ AIFinds freedom-of-information regimes "generally only grant access to existing documents" and that with "no mature standard for documenting AI models," public-sector AI transparency is limited.
- On the Quest for Effectiveness in Human Oversight: Interdisciplinary Perspectives Peer-reviewed✦ AISynthesises interdisciplinary evidence to argue that legally mandated human oversight of AI is often ineffective ('rubber-stamp') unless effectiveness conditions are explicitly designed for.
- Law and the Emerging Political Economy of Algorithmic Audits Peer-reviewed✦ AIAnalyses how AI-audit mandates create a new political economy of auditing, warning that audit markets can entrench rather than constrain power without underlying governance.
- Understanding Contestability on the Margins: Implications for the Design of Algorithmic Decision-making in Public Services Peer-reviewed✦ AIField study shows marginalized public-service users need intermediaries and informal channels for contestation, challenging individualistic right-to-contest designs.
- A future role for health applications of large language models depends on regulators enforcing safety standards Peer-reviewed✦ AIArgues medical LLMs are likely device-like clinical decision support and that 'the urgent need to enforce existing regulations' is the key safeguard against unsafe deployment.
- Contestable AI by Design: Towards a Framework Peer-reviewed✦ AISynthesises contestable-AI research into a generative design framework for AI systems that are "responsive to human intervention throughout the system lifecycle".
+ 36more across this instrument's topics — see the literature index.
References
- Cal. Stats. 2025, ch. 677 (SB 243); Cal. Bus. & Prof. Code, Div. 8, ch. 22.6, §§ 22601–22606 (added by SB 243, approved by Governor Oct. 13, 2025)
- Cal. Bus. & Prof. Code § 22602(b) (added by SB 243) — operator must maintain a protocol preventing production of suicidal-ideation/self-harm content and referring the user to crisis-service providers, published on its website; § 22603 reports referral data to the Office of Suicide Prevention
- Cal. Bus. & Prof. Code § 22602(a) (added by SB 243) — operator must issue a clear-and-conspicuous notification that the companion chatbot is artificially generated and not human where a reasonable person would be misled; § 22602(c) adds, for known minors, a default every-three-hours AI-reminder + break notification
- Cal. Bus. & Prof. Code § 22605 (added by SB 243) — private right of action: a person injured in fact by a violation may sue for injunctive relief, the greater of actual damages or $1,000 per violation, and attorney's fees and costs
Cite this article
6 formats · 1-click copyPersistent identifier: https://policywindow.org/wiki/ca-sb-243 — committed-stable URL with content-versioning via ?asOf= (rollout pending per methodology §7). DOIs via Zenodo are on the roadmap.
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