California and New York Enact a Second Generation of Chatbot Laws Aimed at Protecting Children

New York Governor Kathy Hochul has signed S 9051B into law, establishing restrictions on AI companion chatbot features considered unsafe for minors. The signing comes just over a month after California Governor Gavin Newsom signed SB 1119, a comprehensive chatbot law. The two states, the first to enact AI companion chatbot laws in 2025, are now the first to adopt a second generation of such legislation only a year later. New York's action brings the number of enacted state chatbot-specific laws to 19.

The two states have chosen divergent paths. New York's S 9051B takes a restrictive-by-design approach, prohibiting twelve broadly defined categories of unsafe AI companion features from being provided to minors. These span harmful content, such as outputs that endorse suicide, self-harm, disordered eating, or sexually explicit material, as well as relationship-oriented features, including outputs that suggest a chatbot is human, express personal opinions or emotional appeals, or engage in flattery. The law also restricts the use of a minor's personal information from previous sessions or acquired more than twelve hours earlier.

California's SB 1119, known as Adam's Law, instead builds a governance framework, requiring risk assessments, independent audits, default parental controls, and restrictions on conversational memory and targeted advertising. Both laws require age assurance and focus their measures on minors.

For children and families, the practical questions are significant. New York defines terms such as personal opinions, emotional appeals, flattery, and sycophancy with little guidance, meaning operators may restrict ordinary or beneficial exchanges to stay in compliance. Restrictions on conversational memory may reduce risks of emotional dependence, but could also prevent a chatbot from recalling a disclosed allergy to give a later safety warning. New York's law provides for enforcement by the Attorney General, with civil penalties of up to 25,000 dollars per violation and algorithmic disgorgement. Its effective date was adjusted to June 1, 2027.

The Foundation notes that these competing approaches may shape how other states and Congress legislate next year. This development was reported by the Future of Privacy Forum: Back in the Chat: California and New York Take Diverging Paths in Second Wave of Chatbot Regulations.