AI Chatbot Disclosure Laws: Do You Have to Tell Customers It's a Bot?

The short answer

In a growing number of places, yes. AI chatbot disclosure laws in the EU, Maine and California require you to make clear that a customer is dealing with a bot in many commercial settings, Utah requires it when a customer asks, and Canada has no general bot-disclosure statute but its privacy regulator expects it. The simplest safe practice everywhere is to say it up front, in the first message. This is general information, not legal advice.

Why AI chatbot disclosure laws are spreading

Voice agents and chat assistants now sound human enough that customers can genuinely be misled. Lawmakers have responded in two waves. The first targeted deception in sales and elections. The second, since 2025, targets "companion" chatbots and adds safety duties on top of disclosure. A business running a support bot or an AI receptionist mostly needs to care about the first wave, but should know the second exists.

The rules, jurisdiction by jurisdiction

European Union

Since 2 August 2026, Article 50(1) of the EU AI Act requires providers to design AI systems that interact directly with people so that those people are told they are interacting with AI, unless that is obvious. The information must be clear and given at the latest at the first interaction. It can reach businesses outside the EU when their AI's output is used in the EU; we explain that in our post on EU AI Act Article 50 for non-EU businesses.

California

California has had a bot law since 2019. Under Business and Professions Code section 17941, it is unlawful to use a bot to communicate or interact with a person in California online with intent to mislead them about its artificial identity, in order to incentivise a sale or influence a vote. Disclosure is a complete defence if it is clear, conspicuous and reasonably designed to inform. Section 17940 defines "online" as any public-facing website, web app or digital application, so this is not limited to social media.

Separately, SB 243, signed in October 2025 and in force since 1 January 2026, regulates companion chatbots: notices that the bot is AI-generated, periodic reminders for minors, crisis protocols and a private right of action for families. A standard customer-service bot is not the target, but check if your product leans into ongoing personal conversation.

Utah

Utah's SB 226 (2025), effective 7 May 2025, narrowed the state's earlier rule. A business using generative AI with a consumer must disclose that it is AI, not a human, if the person makes a "clear and unambiguous request" to know. People in state-licensed occupations must disclose proactively when the AI interaction is "high-risk", such as collecting health, financial or biometric data or giving advice people may rely on for significant decisions: verbally at the start of a call, or in writing before a chat. There is a safe harbour if the AI clearly discloses at the outset and throughout. Fines run up to $2,500 per violation. The law also says it is no defence that generative AI made the misleading statement.

Maine

Maine's LD 1727, approved on 12 June 2025, is the broadest general rule in the US so far. A person may not use an AI chatbot or other computer technology to engage in trade and commerce with a consumer in a way that may mislead a reasonable consumer into believing they are dealing with a human, unless the consumer is clearly and conspicuously told otherwise. A breach is a violation of the Maine Unfair Trade Practices Act. "Chatbot" covers text and voice.

New York and the companion-bot wave

New York's AI companion law, in General Business Law Article 47, has applied since 5 November 2025 and requires regular, clear disclosure that the user is not talking to a human. A law-firm survey by Orrick (April 2026) lists further companion or conversational AI laws passed in 2026 in states including Oregon, Washington, Nebraska and Idaho, mostly taking effect in 2027, and notes that nearly all new state laws require clear, up-front disclosure.

Canada

Canada has no general federal or provincial statute that says "disclose your chatbot". But the expectation is clear. The Office of the Privacy Commissioner's principles for generative AI say organisations should make sure users of public-facing tools know they are interacting with AI. Quebec's Law 25 requires notice when a decision about a person is made exclusively by automated processing (see our Quebec Law 25 guide). And misleading consumers is already a problem under general consumer protection law, whoever or whatever does the misleading.

What good disclosure looks like

Putting the strictest rules together gives one practical standard that works almost everywhere:

• First message, every time. "Hi, I am the AI assistant for [business]." For phone agents, say it in the greeting.
• Keep it visible. A persistent "AI assistant" label in the chat header meets Utah's "throughout" safe harbour wording.
• Answer honestly when asked. Never script a bot to claim it is human. That is the conduct every one of these laws targets.
• Offer a human route. Not always legally required, but customers trust a bot more when escape is easy. We cover the design side in AI customer service that works.
• Do not bury it. Terms-and-conditions disclosure fails the "clear and conspicuous" tests.

A human-sounding name and voice are fine. Pretending to be a person is not.

Key takeaways

• The EU and Maine effectively require up-front disclosure for customer-facing bots; California targets misleading bots used to sell.
• Utah requires disclosure on request, and proactively for high-risk licensed services.
• Companion chatbots face extra rules in California, New York and a growing list of states.
• Canada relies on regulator guidance and general law, so disclosure is still the safe default.

Frequently asked questions

Is it illegal for a chatbot to pretend to be human?

In many places it can be. Maine treats misleading consumers about whether they are talking to a human as an unfair trade practice, California bans bots that mislead about their identity to drive sales, and the EU requires disclosure unless it is obvious. Even where no specific law exists, deceptive practices rules can apply.

Do AI phone receptionists have to disclose they are AI?

The EU rule and Maine's law both cover voice, and Utah requires a verbal disclosure at the start for high-risk interactions in regulated occupations. A one-line spoken greeting that says it is an AI assistant is the easiest way to comply.

Does Canada require chatbot disclosure?

There is no general statute as of October 2026. The federal privacy commissioner's generative AI principles expect public-facing tools to tell users they are interacting with AI, and Quebec requires notice for exclusively automated decisions about people.

Sources

1. Article 50: Transparency Obligations for Providers and Deployers of Certain AI Systems — EU Artificial Intelligence Act (artificialintelligenceact.eu)
2. Business and Professions Code section 17941 — California Code (public.law)
3. S.B. 226 Artificial Intelligence Consumer Protection Amendments (Enrolled Copy) — Utah State Legislature, 2025
4. An Act to Ensure Transparency in Consumer Transactions Involving Artificial Intelligence (LD 1727, Public Law c. 294) — Maine Legislature, 12 June 2025
5. First-in-the-Nation AI Chatbot Safeguards Signed into Law — Office of Senator Steve Padilla, 13 October 2025
6. 2026 State Chatbot Laws: Key Provisions and Regulatory Trends — Orrick, 29 April 2026
7. Principles for responsible, trustworthy and privacy-protective generative AI technologies — Office of the Privacy Commissioner of Canada, 7 December 2023

How Flowmatix can help

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