Sheppard Mullin·TECHNOLOGY / AI

California Enacts AI Spokesperson, Chatbot, and Content Disclosure Laws

California lawmakers have approved three AI regulations that require clear disclosure when chatbots or AI-generated content is used publicly, with some provisions taking effect Jan 1 2027 and one effective immediately.

California has passed a trio of AI civil‑disclosure statutes that represent the most aggressive regulatory push yet for AI communication. The "California AI Spokesperson Act" makes it a civil or criminal offense for any public-facing entity—corporate, non‑profit, or individual—to use an AI system to produce spoken comments or written text without clearly labeling its origin as AI. The "AI Chatbot Disclosure and Conduct Regulations" require businesses and apps that host chatbots to provide users with a conspicuous, understandable disclosure that the chatbot is AI‑driven, how it processes data, and how users can opt‑out. The newly effective "AI Content Disclosure Act," which took effect immediately, imposes similar requirements on any AI‑generated textual or audiovisual content, mandating that the creator or publisher disclose the AI involvement. These statutes impose substantial new due‑diligence, content‑review, and privacy‑data‑security obligations for clients deploying AI products or services in California. Firms should revise internal compliance protocols, audit existing AI systems for labeling and data‑transparency, and consider drafting AI‑use agreements that address these disclosure requirements by the Jan‑1 2027 start date or immediately, depending on the rule. Clients should also monitor potential federal or multi‑state adoption of corresponding AI disclosure regimes, as the California model may set a broader precedent.

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Read the original firm alert → Thursday, October 29, 2026

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