The Rest of the West: Oregon and Washington Build on California Chatbot Law

The West Coast now has a full set of chatbot laws on the books. Following California’s SB 243 (signed in 2025 and effective January 1, 2026) both Oregon (SB 1546) and Washington (HB 2225) enacted companion chatbot laws that will take effect on January 1, 2027. Together, these laws establish a new framework for regulating chatbot interactions with minors.

California’s SB 243 set the stage for regulating chatbots in the U.S., building on earlier legislative momentum (including in New York) to introduce a framework centered on disclosures and safety protocols, such as connecting users to crisis hotlines when they express suicidal ideation. For a deeper dive into SB 243 and its key provisions, see our previous FPF blog post. 

Oregon and Washington retain many of the core elements of SB 243 but take the framework significantly further, expanding into new areas such as content restrictions and engagement design. Washington’s HB 2225, in particular, introduces a more expansive regulatory approach that will likely require companies to make design changes to their chatbots. While these laws are framed around “companion chatbots” and largely focus on minors, their reach may be broader than first appears. Even systems that are not labeled or designed as companion chatbots could be implicated, depending on how they function in practice. 

This blog post compares Oregon’s SB 1546 and Washington’s HB 2225, while providing context from California’s SB 243, across the laws’ scope, requirements, and enforcement. While the laws are similarly scoped, their requirements diverge in meaningful ways, creating potential compliance challenges (especially where provisions are ambiguous or require interpretation). Key takeaways include:

• Scope: California and Washington take a broader, capability-based approach to define companion chatbots, while Oregon uses a narrower, behavior-based definition with more carve-outs, making its scope more targeted.
• Requirements: All three include disclosures and self-harm protocols, but Washington is the most prescriptive (e.g., additional requirements on engagement design, safeguards), and California is the most limited and disclosure-focused.
• Enforcement: All three enforce via a private right of action, with California and Washington including statutory damages, while Washington relies on its Consumer Protection Act for enforcement.