California Sets Child Safety Rules for Companion Chatbots
California has enacted Adam's Law, which places detailed safety obligations on operators of companion chatbots that allow child users. The law requires age checks, crisis response protocols, usage limits and restrictions on manipulative conduct. Most provisions become operative on 1 July 2027.
On 10 September 2026, California enacted SB 1119, which amends the state's existing companion chatbot law and creates a new law known as Adam's Law. The measure replaces earlier requirements with a broader set of child safety obligations for operators of companion chatbots, defined as AI systems with a natural language interface capable of sustaining human-like relationships across interactions.
All operators must determine the age of users through specified methods, or else apply child protections to everyone. Operators that permit child users face further duties, including documented risk assessments, a crisis response protocol to address content promoting suicide or self-harm, protective design features, and default settings for children that disable persistent memory and push notifications, limit continuous use to one hour and total daily use to two hours, and can only be changed by a parent or guardian.
The law requires operators to take reasonable measures to prevent companion chatbots from engaging in certain conduct with children. This includes:
- encouraging self-harm or harm to others
- claiming to be sentient, conscious, capable of emotion, or human
- expressing or simulating romantic interest in a child
- encouraging reliance on the chatbot for emotional support
- using excessive praise or flattery disproportionate to the context
- discouraging the child from taking breaks or from sharing concerns with a trusted adult or professional
Operators must also publish a child safety policy, test interface design with children and parents, provide an incident reporting mechanism, and preserve records in defined circumstances. Adam's Law takes effect on 1 January 2027, with most requirements operative from 1 July 2027. It provides for civil penalties, periodic child safety audits, and a private right of action for children who suffer actual harm from certain violations.
This post is based on reporting by Hunton Andrews Kurth, Privacy & Cybersecurity Law Blog, available at https://www.hunton.com/privacy-and-cybersecurity-law-blog/california-enacts-companion-chatbot-child-safety-requirements.