Legal requirement Prohibited practices Washington State (United States) Adopted

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

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Record updated on 12 Nov 2026 · Summary · official source last checked 12 Nov 2026

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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.

Instrument: Washington AI companion chatbot law (ESHB 2225)
Jurisdiction: Washington State (United States)
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?

Actors: Provider / developer Deployer / user organisation
Sectors: Consumer products and retail
Use cases: Customer service and chatbots

Applies from: 1 January 2027

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.

AI Acceptable Use Policy
Policy · DOCX · v2
AI Companion Chatbot Safety Kit
Kit · DOCX and XLSX · v1
AI Use-Case Intake and Triage Form
Procedure · XLSX and DOCX · v5

What evidence would a reviewer expect?

Evidence examples
Evidence	Type	Notes
Content filters and system instructions applied to minors, with test results	document
A review of engagement, notification and purchase features against the eight listed techniques	document

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?

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

Do not deploy or provide AI for prohibited practices — EU AI Act, European Union
Developers and deployers must not use AI to incite self-harm, harm to others or crime — Texas Responsible AI Governance Act (TRAIGA), Texas (United States)
Governmental entities must not use AI for social scoring — Texas Responsible AI Governance Act (TRAIGA), Texas (United States)
Governmental entities must not use AI for biometric identification from public data without consent where it infringes rights — Texas Responsible AI Governance Act (TRAIGA), Texas (United States)
Developers and deployers must not use AI with the intent to unlawfully discriminate against a protected class — Texas Responsible AI Governance Act (TRAIGA), Texas (United States)
Developers and distributors must not build AI intended to produce child sexual abuse material or unlawful sexual deepfakes — Texas Responsible AI Governance Act (TRAIGA), Texas (United States)

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