California's SB 243, the nation's first law targeting AI companion chatbots, has been in effect for six months since January 1, 2026 — and the companion industry now faces a tri-state regulatory framework. Oregon's SB 1546 and Washington's HB 2225, both signed in March 2026, take effect on January 1, 2027, creating a West Coast compliance patchwork that every AI girlfriend, companion, and NSFW chatbot operator must navigate.
What SB 243 Requires Today
California's law applies to any operator making a companion chatbot available to users in the state. Since January 1, 2026, operators must:
- Disclose AI status — A clear notice that the chatbot is AI-generated, required when a reasonable person could mistake it for a human.
- Issue break reminders to minors — For known minors, a break reminder every three hours during continuous interaction.
- Display suitability warnings — A disclaimer that companion chatbots may not be suitable for some minors.
- Publish crisis prevention protocols — Operators must maintain and publicly post protocols to prevent generation of suicidal ideation or self-harm content, with referrals to crisis services.
- Prevent sexually explicit content for minors — Guardrails against generating explicit visual material or suggesting sexual conduct.
- Ban manipulative engagement — No unpredictable reward loops or design features that maximize engagement through addiction.
The law includes a private right of action — individuals can sue for at least $1,000 per violation. The first annual compliance reports to the California Office of Suicide Prevention are due July 1, 2027.
Major platforms have stated compliance. Replika uses content-filtering systems and crisis resource guardrails. Character.AI includes disclaimers that all chats are AI-generated. But no public enforcement actions or lawsuits have been reported in the first six months.
Oregon and Washington Raise the Bar
Oregon's SB 1546 and Washington's HB 2225, both signed in March 2026, build on California's framework but add significant differences. Companion apps have six months to prepare before the January 1, 2027 effective date.
Oregon SB 1546 casts the widest net. It applies if the operator "knows or has reason to believe" a user is a minor — including behavioral or contextual cues. Unique requirements include:
- Mandatory conversation interruption — When suicidal ideation is detected, the chatbot must halt the conversation to deliver crisis referrals. No other state requires this.
- Parental controls — Platforms must block minors unless a parent consents, and parents get controls to view history, set time limits, and delete accounts.
- AI disclosure every 3 hours — Same frequency as California for break reminders.
- Statutory damages of $1,000 per violation with a private right of action.
Washington HB 2225 takes a different approach. It applies only when the operator "knows" the user is a minor, or the chatbot is "directed to minors." Key differences:
- Hourly AI disclosure — Washington requires the AI notification every hour for minors, the strictest frequency in the country.
- Expanded content ban — No "suggestive dialogue" with minors, going beyond California's prohibition on explicit content.
- Anti-manipulation — Prohibits techniques that prolong an emotional relationship, with specific examples provided.
- No mandatory conversation interruption for crisis detection (unlike Oregon).
What This Means for Companion App Operators
An app available across all three states must comply with three different regimes simultaneously. The variation in disclosure frequency (hourly in Washington vs. every 3 hours in California and Oregon), minor identification standards, and crisis response protocols creates genuine operational complexity. A chatbot that interrupts conversations for Oregon users would not need to do so for Washington users.
For NSFW-focused companion apps, the restrictions on content for minors are already in effect in California, and Oregon and Washington will add suggestive-dialogue and parental-consent requirements. Apps serving adult users only must verify age robustly to avoid triggering the minor-protection provisions — age verification is no longer optional.
The broader trend is clear: companion chatbot regulation is now a West Coast reality, and more states are likely to follow. Companion app operators who treat compliance as a one-state problem are setting themselves up for risk.