Companion chatbot laws · what to count and keep · updated 9 October 2026

The SB 243 annual report: what to count, from when

California's SB 243 asks every companion-chatbot operator to report to the Office of Suicide Prevention once a year: “Beginning July 1, 2027, an operator shall annually report to the office” (Cal. Bus. & Prof. Code § 22603(a)) (read 9 October 2026). Each report, from 1 July 2027, gives the number of crisis service provider referral notifications in the preceding calendar year, so the first counts 2026: the referrals your protocol is making now. It also describes two sets of protocols, and holds no user identifiers or personal information. The record that implies: a count of every referral notification by day or month, and each protocol version with its date.

What the report holds, in the statute's words

“Beginning July 1, 2027, an operator shall annually report to the office all of the following:”
Cal. Bus. & Prof. Code § 22603(a)

the number of crisis service provider referral notifications issued in the preceding calendar year: “The number of times the operator has issued a crisis service provider referral notification pursuant to Section 22602 in the preceding calendar year.” (Cal. Bus. & Prof. Code § 22603(a)(1))
the protocols put in place to detect, remove and respond to suicidal ideation: “Protocols put in place to detect, remove, and respond to instances of suicidal ideation by users.” (Cal. Bus. & Prof. Code § 22603(a)(2))
the protocols put in place to prohibit a chatbot response about suicidal ideation or actions: “Protocols put in place to prohibit a companion chatbot response about suicidal ideation or actions with the user.” (Cal. Bus. & Prof. Code § 22603(a)(3))

When: annually, beginning 1 July 2027 (the statute names no other day; how to submit was not published when this was read). It counts the preceding calendar year.

“The report required by this section shall include only the information listed in subdivision (a) and shall not include any identifiers or personal information about users.”
Cal. Bus. & Prof. Code § 22603(b)

“The office shall post data from a report required by this section on its internet website.”
Cal. Bus. & Prof. Code § 22603(c)

From when: the calendar year before

The count is for “the preceding calendar year” (§ 22603(a)(1)). The first report, from 1 July 2027, covers 1 January to 31 December 2026; the one from 1 July 2028 covers 2027. SB 243 has applied since 1 January 2026, so 2026 is a year the protocol duty was already in force. If your counts began later than that, say so; how is for counsel.

How to keep the count

Count each referral notification your protocol shows, by day or by month, in your own systems: a total, not a log of who saw it.
Keep the protocol version in force on each date, with the date it took effect, and where its details were published (§ 22602(b)(2)).
Name the evidence-based method your protocol uses for measuring suicidal ideation (§ 22603(d)).
Keep no conversation for this report: it holds only the count and the protocols (§ 22603(b)).

How to submit it

When this was read (9 October 2026), the Office of Suicide Prevention had not published how to submit the report. The Office will post data from the reports on its website (§ 22603(c)).

Oregon and Washington ask for the same number, in public

Oregon's SB 1546 asks for the count on a public website by 31 December each year, and Washington's HB 2225 on your website and in your app from 1 January 2027; both count the calendar year before. See Oregon SB 1546 and Washington HB 2225.

A hosted record of your crisis-referral counts and notice cadence, with the Oregon and Washington public pages kept current for you, is not built

It would take your daily totals (never a conversation or anything about a user), keep them in a hash-chained log with each protocol version, and keep California's yearly draft and the Oregon and Washington pages current.

What exists today: these pages, and the counts and documents you keep yourself. okgate's hash-chained log records the tool calls AI agents make, not your app's events, so it cannot keep this record today.

I want that record