ARTICLE
20 April 2026

Oregon Joins the AI Companion Wagon

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Sheppard, Mullin, Richter & Hampton LLP

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Oregon has enacted legislation requiring AI companion platforms to disclose when users are interacting with artificial intelligence rather than humans, with stricter requirements for minor users including mandatory break reminders and prohibitions on appearing human. The law, effective January 2027, establishes protocols for addressing mental health concerns and creates a private right of action with $1,000 per violation damages.
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Oregon has followed Washington in enacting an AI companion law. The law will go into effect on January 1, 2027. AI companions are defined as those that are simulate sustained, human-like relationships with a user. The law expressly excludes platforms whose sole purpose is customer support, or stand-alone speaker devices that act as virtual assistants. It also excludes chat features within video games, as long as they do not respond to topics like mental health or self-harm.

The Oregon law regulates companies that provide AI companions to state residents. Namely, if the residents would otherwise think the companion is a human, then the company must disclose that the resident is interacting with AI, and not a human. Other requirements exist, like having protocols in place to identify and address suicidal ideation or self-harm. Additional requirements apply if the user is a minor, including ensuring that the companion does not appear to be human. For example, by stating that the AI is a human. It must also remind minor users that they are interacting with AI every three hours and tell the user to take a break from interacting with the AI.

The law provides for a private right of action, with damages of $1,000 per violation.

Putting It Into Practice: This law underscores states’ growing concerns with AI tools that mimic or replace human interaction. The scope of this law is narrow. That said, given the private right of action under this law, as well as the similar law in Washington, it should not be ignored. Thus, if companies have not already inventoried their current communication tools to understand the AI features, this may be a good reminder to do so.

 

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