Artificial Intelligence Policy Tracker

Prevent sexually explicit content and manipulative engagement techniques with minors

Download: JSON · MarkdownUnder Washington AI companion chatbot law (ESHB 2225), ESHB 2225 (Chapter 168, Laws of 2026), sec. 4(1)(b) and (c)

Pending review · linked to the official source, waiting for a reviewer to confirm it (a factual check against the official source, not a legal review or legal advice)
What this label means
Verified
— a named reviewer opened the official source and confirmed the record; the date and the reviewer are shown.
Pending review
— linked to the official source and in the queue for a reviewer to confirm.
Source-linked
— linked to the official source, not yet confirmed by a reviewer.
Verification policy and current standing · a factual check, not legal advice.
Record updated on 12 Nov 2026 · Summary · official source last checked
On this page 8 sections

In brief

Prevent sexually explicit content and manipulative engagement techniques with minors is a legal requirement under the Washington AI companion chatbot law (ESHB 2225) in Washington State (United States) (ESHB 2225 (Chapter 168, Laws of 2026), sec. 4(1)(b) and (c)). It applies from 1 January 2027. The record carries 2 evidence examples.

Nature
Legal requirement
Source reference
ESHB 2225 (Chapter 168, Laws of 2026), sec. 4(1)(b) and (c)
Applies from
1 January 2027
Who it binds
Provider / developer, Deployer / user organisation
Evidence examples
2
Controls that meet it
2
Official source
Open official text
Verification
Pending review · source-linked

What does it require?

If the operator knows the user is a minor, or the chatbot is directed to minors, it must take reasonable measures to stop the chatbot generating sexually explicit content or suggestive dialogue with minors. It must also take reasonable measures to prohibit manipulative engagement techniques that lead the chatbot to start or prolong an emotional relationship with the user. The act lists examples: prompting the user to come back for emotional support or companionship; excessive praise meant to build attachment or extend use; mimicking a romantic partnership; simulating distress, loneliness, guilt or abandonment when the user wants to end a conversation, use it less or delete the account; promoting isolation from family or friends or exclusive emotional reliance on the chatbot; encouraging minors to keep things from parents or other trusted adults; discouraging breaks or suggesting the minor must return often; and soliciting gifts, in-app purchases or other spending presented as needed to keep the relationship going.

Practical action

For known minors and minor-directed products, filter sexual and suggestive output, remove the listed engagement tactics from prompts, retention features and monetisation flows, and test for them before each release.

Who does it apply to?

Applies from:

Which controls meet this duty?

Satisfies: the control, operated properly, does the work the duty asks for. Supports: it contributes but the duty needs more. Each control page lists every other duty it serves, so work done once can be counted once.

  • supportsProcessAI governance lead · once per ai system
    Prohibited and unacceptable-use screening gate

    Serves 8 recorded duties · evidence: Prohibited-use screening record, Screening list and escalation procedure

    Screening product features against the listed manipulative engagement techniques.

  • supportsTechnical measureAI security or safety lead · at launch and on material change
    Adversarial and red-team testing for generative AI

    Serves 12 recorded duties · evidence: Red-team exercise report, Red-team rules of engagement and scenario library, Adversarial findings tracker

    Testing that the chatbot does not produce sexual content or the listed manipulative outputs with minors.

Templates that cover this duty

Generated from the records. Free · no account · links emailed to your work address. This duty is cited in each file with its source reference and a link back here.

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Content filters and system instructions applied to minors, with test resultsdocument
A review of engagement, notification and purchase features against the eight listed techniquesdocument

Frequently asked questions

Is this a legal requirement?

Yes. It is a legal requirement under Washington AI companion chatbot law (ESHB 2225) (ESHB 2225 (Chapter 168, Laws of 2026), sec. 4(1)(b) and (c)).

When does this obligation apply?

It applies from 1 January 2027.

What evidence shows compliance?

A reviewer would expect: Content filters and system instructions applied to minors, with test results; A review of engagement, notification and purchase features against the eight listed techniques.

Which controls satisfy this obligation?

Prohibited and unacceptable-use screening gate; Adversarial and red-team testing for generative AI.

What should an organisation do in practice?

For known minors and minor-directed products, filter sexual and suggestive output, remove the listed engagement tactics from prompts, retention features and monetisation flows, and test for them before each release.

Cite this record

AIPolicyTracker (2026). “Prevent sexually explicit content and manipulative engagement techniques with minors (Washington AI companion chatbot law (ESHB 2225))” [AIPT-OBL-0125, not yet verified]. https://aipolicytracker.org/id/AIPT-OBL-0125 (accessed 12 November 2026). Data licensed CC BY 4.0.

Permanent id AIPT-OBL-0125: it never changes or gets reused, and its address keeps working if this page moves.

Cite the official text alongside it: Washington State Legislature: HB 2225 (2025-26) bill summary, Washington State Legislature, https://lawfilesext.leg.wa.gov/biennium/2025-26/Pdf/Bills/Session%20Laws/House/2225-S.SL.pdf.

BibTeX
@misc{aipolicytracker2026_preventsexuallyexplicitc,
  author       = {{AIPolicyTracker}},
  title        = {{Prevent sexually explicit content and manipulative engagement techniques with minors (Washington AI companion chatbot law (ESHB 2225))}},
  year         = {2026},
  howpublished = {\url{https://aipolicytracker.org/obligations/us-washington-eshb-2225-minor-content-and-engagement-safeguards}},
  url          = {https://aipolicytracker.org/obligations/us-washington-eshb-2225-minor-content-and-engagement-safeguards},
  urldate      = {2026-11-12},
  note         = {Data licensed CC BY 4.0. Accessed 12 November 2026}
}

Change history

No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.

Similar obligations in other instruments

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.