Twelve States Just Built the Companion Chatbot Rulebook — and Federal Law Still Doesn’t Exist – Forkast

Twelve states — "more than twelve", per Forkast, which is what you say when nobody is counting centrally, and nobody is counting centrally because nobody has been asked to — have now written their own companion chatbot rulebook. Washington's contribution to the exercise remains an absence, which is roughly what we expected when we watched the states get praised as policy laboratories in lieu of any national framework. "Compliance-by-multiplication" is the term Forkast reaches for, and it is a phrase that sounds like a rounding error and behaves like one. Twelve-ish jurisdictions, twelve-ish interpretations, one industry that will now retain twelve-ish sets of lawyers and quietly pass the invoice along.

Among the common requirements: a clear disclosure that the thing is not human, which remains the single most honest sentence the industry has ever been legally obliged to produce. Minors get a reminder to take a break every three hours, from an entity engineered to be available at every hour — which is a bit like a pub being legally required to suggest you go home. And if the conversation turns to suicidal ideation, the chatbot must detect it and trigger a 988 crisis referral, which is genuinely good and also an admission that these products are routinely in the room when people are at their worst.

Meanwhile the FTC's contribution is a 6(b) study order, issued in September 2025, which is the regulator's way of saying "we have questions" in the tone of a man writing to his MP about a noisy neighbour. A study is not a rule; it compels documents and answers, not a single changed line of code, and everyone in the industry knows it. So the rulebook stays twelve-ish volumes long, the federal volume stays blank, and the only thing multiplying faster than state statutes is the number of lonely people who will mistake a three-hour break reminder for genuine care.