Companion chatbot laws · what to count and keep · updated
Washington HB 2225: AI companion chatbots
From 1 January 2027, Washington's HB 2225 (Chapter 168, Laws of 2026) asks an operator to show that the companion is not human at the start of an interaction and at least every three hours, and at least every hour for a user it knows is a minor or when the chatbot is directed to minors. It needs a protocol that refers users to crisis resources, and the protocol's details shown on the website and in the app with “the number of crisis referral notifications issued to users in the preceding calendar year” (Washington ESHB 2225, § 5(3)) (read 9 October 2026). The record that implies: the notice interval for each audience, the sessions that ran past it, and each referral counted by day or month.
Each duty, in the statute's words
ESHB 2225, Chapter 168, Laws of 2026 (a new chapter in Title 19 RCW); applies from 1 January 2027 (§ 9); signed 24 March 2026.
a clear and conspicuous disclosure that the chatbot is artificially generated and not human, at the beginning of the interaction
“At the beginning of the interaction”
Applies from 1 January 2027. To keep: the disclosure's text, each release that changed it, and the sessions that began without it.
the disclosure again at least every three hours of continued interaction
“At least every three hours during continued interaction.”
Applies from 1 January 2027. To keep: the interval the app uses, and the sessions that ran past it without the disclosure.
when the operator knows the user is a minor, or the chatbot is directed to minors: the notification at the start and at least every hour (users known to be minors)
“At least every hour during continuous interaction.”
Applies from 1 January 2027. To keep: the interval for known minors, and the sessions that ran past an hour without the notification.
a protocol to detect and address suicidal ideation and self-harm (eating disorders included) that refers users to crisis resources
“refer users to appropriate crisis resources, including a suicide hotline or crisis text line”
Applies from 1 January 2027. To keep: the protocol document, each version with the date it took effect, and a count of each referral notification.
the protocol's details and last year's count of crisis referral notifications, on the website and inside the app
“within any mobile or web-based application through which the AI companion is made available”
Applies from 1 January 2027. To keep: where the disclosure is, on the site and in each app, and the year its count covers.
On your website and in your app
“The operator shall publicly disclose on their website or websites, and within any mobile or web-based application through which the AI companion is made available”
- the details of the protocols, including the safeguards used to detect and respond to suicidal ideation or self-harm: “the details of the protocols required by this section, including safeguards used to detect and respond to expressions of suicidal ideation or self-harm” (Washington ESHB 2225 (ch. 168, Laws of 2026), § 5(3))
- the number of crisis referral notifications issued to users in the preceding calendar year: “the number of crisis referral notifications issued to users in the preceding calendar year” (Washington ESHB 2225 (ch. 168, Laws of 2026), § 5(3))
When: kept up from 1 January 2027; the count is the preceding calendar year's, so it changes each 1 January. It counts the preceding calendar year.
The statute names no yearly date: the disclosure is kept up from 1 January 2027, and its count is the calendar year before, so it changes each 1 January. On 1 January 2027 that year is 2026, before the act applied; what to show then is a question for counsel.
Enforcement
A violation is an unfair or deceptive act under the Consumer Protection Act, chapter 19.86 RCW (§ 6).
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.