California SB 243 (Companion Chatbots): Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under California SB 243 (Companion Chatbots). Not legal advice; verify with counsel before acting.

1. Confirm scope: does the law apply to your operations? See Who Must Comply or use the Compliance Checker.
2. Inventory in-scope AI systems and classify them by role (developer/deployer) and decision type.
3. Address each obligation:
   • disclosure — Issue a clear and conspicuous notification that a companion chatbot is artificially generated and not human whenever a reasonable person would be misled into believing they are interacting with a human, and disclose that companion chatbots may not be suitable for some minors.Cal. Bus. & Prof. Code §§ 22602(a), 22604
   • governance — Maintain, and publish details of, a protocol that prevents a companion chatbot from producing suicidal ideation, suicide, or self-harm content, including referral to crisis service providers when a user expresses suicidal ideation or self-harm.Cal. Bus. & Prof. Code § 22602(b)
   • documentation — Beginning July 1, 2027, report annually to the Office of Suicide Prevention the number of crisis-service referral notifications issued in the prior calendar year and the protocols used to detect, remove, and respond to suicidal ideation, without user identifiers.Cal. Bus. & Prof. Code § 22603
4. Adopt a federal control framework: NIST AI RMF or ISO/IEC 42001 to demonstrate due care.
5. Document evidence of compliance for each obligation, refreshed at the cadence the law requires.
6. Build the AG-notification path if the law requires it (Colorado, California SB 53).
7. Set the refresh cadence — annual for most impact-assessment regimes; continuous for monitoring.