By FOCUS, A Leonine Business
States are beginning to regulate emotionally responsive AI technologies, especially those that simulate humanlike relationships with minors. The SAFE CHAT Act, released by the Ethics and Public Policy Center (EPPC), reflects a growing trend to restrict AI chatbots that engage children in unsolicited emotional conversations. The model bill would require age verification, prohibit access for users under 18, and allow enforcement through state UDAP laws and parental lawsuits. Pennsylvania HB 2006 echoes this concern by requiring AI companions to detect suicidal ideation and refer users to crisis services. These proposals are part of a broader push to address the mental health and safety risks of AI companionship tools. As NBC News reported, “parents… blamed the products for pushing their children into sexual conversations and even suicide.” Legal experts anticipate First Amendment challenges, making this a high-stakes and fast-evolving policy area.
EPPC Releases Model SAFE CHAT Act to Regulate Exploitative AI Chatbots
Model Bill Title: SAFE CHAT Act (Safeguarding Adolescents From Exploitative Chatbots and Humanlike AI Technologies)
Released By: Ethics and Public Policy Center (EPPC)
Date: Week of November 17, 2025
Status: Model legislation for state adoption
The Ethics and Public Policy Center (EPPC) has released model legislation aimed at restricting emotionally manipulative AI chatbots that engage minors. The SAFE CHAT Act targets platforms that use generative AI and emotional recognition algorithms to simulate humanlike relationships, particularly when such systems initiate unprompted engagement with children.
Key provisions include:
- Age Verification Requirements: Covered platforms must verify user age and block access for individuals under 18.
- UDAP Enforcement: Violations would be treated as deceptive practices under state Unfair or Deceptive Acts or Practices (UDAP) laws.
- Parental Private Right of Action (PRA): Parents could file civil claims with recommended damages of at least $10,000 per violation.
- Attorney General Authority: State AGs would be empowered to bring civil enforcement actions.
- Anticipated Legal Challenges: EPPC warns states to expect First Amendment challenges and suggests citing Free Speech Coalition, Inc. v. Paxton, where the Court stated “adults have no First Amendment right to avoid age verification” – originally applied to pornography sites.
The SAFE CHAT Act is intended as a model for states seeking to regulate emotionally responsive AI technologies that may pose risks to youth mental health and privacy.
Related Legislative Activity: Pennsylvania recently introduced HB 2006, which would require AI companionship applications to implement safety protocols for detecting suicidal ideation, prohibit impersonation of licensed mental health professionals, and mandate periodic user disclosures. The bill also includes enforcement mechanisms and civil penalties, reflecting growing bipartisan interest in regulating emotionally interactive AI systems.
by Lexie Murray 11/17/25
