Oregon's AI companion chatbot law: what SB 1546 says

Informational only, not legal advice. TacticalMS is not a law firm. Read more.

Oregon's Legislature passed Senate Bill 1546, "Relating to artificial intelligence companions," during the 2026 session ¹. It is one of a small group of state laws written specifically for chatbots built to act like a friend, partner or confidant, and it takes effect on January 1, 2027 ^{3, 4}.

The law matters well beyond companion apps because its key question is a definition: which chatbots count as an "artificial intelligence companion"? Businesses that use chat tools, and the firms that advise them, have started reading that definition closely ^{3, 4}. This post summarizes what the law and published commentary say. It does not answer whether any particular product is covered. For the separate ethics guidance on law firm chatbots, see our guide to OSB Formal Opinion 2026-208.

Who it covers

The enrolled bill defines an artificial intelligence companion as "a system that uses artificial intelligence, generative artificial intelligence or algorithms that recognize emotion from input" to simulate a sustained, human-like relationship ². The Future of Privacy Forum's comparison chart describes the test as behavior-based: the system remembers prior sessions and preferences, asks unprompted questions about emotional topics, and keeps up ongoing dialogue about personal matters ³.

An "operator" is "a person that controls or makes an artificial intelligence companion" available to users in Oregon ^{2, 3}.

The bill also lists exclusions. Among them are "Software that operates solely for the purpose of customer service or support," certain video game features, and stand-alone smart speakers ². The FPF chart lists further excluded purposes, including education, financial services, business operations, productivity and technical assistance ³. How those exclusions apply to a specific tool is not something a summary can settle. That depends on the text and on advice from a licensed Oregon attorney.

What operators must do

Based on the bill and the summaries from Miller Nash and FPF ^{2, 3, 4}:

• Say it's AI. When a reasonable person could believe they are talking with a human, the operator must give a "clear and conspicuous notice" that the output is artificially generated ².
• Have a self-harm protocol. Operators need an evidence-based protocol to detect suicidal or self-harm ideation, prevent content that encourages it, and refer users to the 988 Suicide and Crisis Lifeline, with a youth line option for younger users. The protocol details must be published on the operator's website ^{3, 4}.
• Protect minors. When an operator knows or has reason to believe a user is under 18, the law adds duties: telling the minor at the start that they are talking with AI, a break reminder at least every three hours, steps to prevent sexual content, and limits on engagement tactics such as reward loops and simulated distress when a user tries to leave ^{3, 4}.
• Report each year. "Not later than December 31 of each year," operators must post a public report covering the prior year, including the number of crisis referrals. The FPF chart notes reports may not include personal information ^{2, 3}.

How it is enforced

There is no Attorney General enforcement provision, according to Miller Nash ⁴. Instead, a person who suffers an ascertainable loss of money or property, or other injury, may sue. The bill provides "statutory damages of $1,000 for each violation," with recovery of the greater of actual or statutory damages, plus injunctive relief, and courts may award attorney fees and costs ^{2, 3, 4}.

How it compares

FPF compared SB 1546 with two neighboring laws ³:

• Washington HB 2225 also takes effect January 1, 2027, but is enforced through Washington's Consumer Protection Act and has no explicit statutory damages amount ³.
• California SB 243 took effect January 1, 2026, and, like Oregon's law, includes a private right of action with $1,000 per violation in statutory damages ³.

What the law does not settle

The commentary so far focuses on the definition and the exclusions ^{3, 4}. Until Oregon courts read the law, there is no case law on where its lines fall. Firms and businesses with questions about a particular tool can read the bill text on the Legislature's site ¹ and talk with a licensed Oregon attorney.

Not legal advice. This post is general information about law and technology, not legal advice. It does not create an attorney-client relationship, and TacticalMS is not a law firm. Laws, rules and ethics opinions change; check the cited sources and talk with a licensed Oregon attorney about any specific situation. Researched and drafted with AI tools from the sources above and checked against our editorial standards. Spot an error? Email intake@tacticalms.dev and we'll fix it.