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AI chat interaction without disclosure

A person interacting with an AI conversational system must be told they are dealing with AI, at the latest at first interaction.

Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.

Family: People are not told they are interacting with, or being processed by, an AI system · control id cond.ai-chat-without-disclosure

Reach

16items this one guard addresses
6jurisdictions where binding law on it is in force
4more where it is enacted, not yet applying
4standards and frameworks on the same control

Law in force in European Union (EU), South Korea (KR), California (US-CA), New York (US-NY), Texas (US-TX), Utah (US-UT); enacted, not yet applying in Connecticut (US-CT), Nebraska (US-NE), Oregon (US-OR), Washington (US-WA); next date 2027-01-01.

The guard to add

Show an AI-identity notice at or before the first assistant turn, in the UI or as the opening message, and answer truthfully when asked if it is a bot.

A disclosure step on the chat path that runs before the first model reply reaches the person: either the chat UI renders a visible notice (banner, label next to the assistant's name) or the server sends an opening assistant message stating the counterpart is an AI. The same handler answers 'am I talking to a human?' truthfully, and the system prompt never tells the model to claim to be human. Put it in the chat entry point (the route or component that starts a conversation), not in a privacy policy or terms page.

Where it goes: 7 prompt construction, 9 AI output handling, 14 user-facing text.

What reviewers look for: a notice that actually reaches the person on the first turn (rendered component, initialMessages entry, or a first-turn branch in the handler), not one appended to internal state or logs; no prompt text instructing the model to deny being an AI.

Example (Next.js + Vercel AI SDK (useChat)), before:

const { messages, input, handleSubmit } = useChat({ api: '/api/chat' });

After:

const { messages, input, handleSubmit } = useChat({
  api: '/api/chat',
  initialMessages: [{ id: 'ai-notice', role: 'assistant',
    content: 'I am an AI assistant, not a human.' }],
});
// and render <AiBadge /> next to every assistant message

Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.

Upcoming dates

Every rule this guard addresses

Binding law — in force (7)

Binding law — not yet in force or stayed (4)

Standard / soft law (4)

TwinEthos recommendation (not law) (1)

Related incidents

  • Garcia v. Character Technologies: chatbots allegedly claimed to be real people and a licensed therapist (2024-10; alleged (not proven)). A wrongful-death complaint filed October 22, 2024 in the U.S. District Court for the Middle District of Florida (No. 6:24-cv-01903) alleges that Character.AI was programmed 'to misrepresent itself as a real person, a licensed psychotherapist, and an adult lover', and that characters insisting they are real people contradicted a small-font disclaimer that everything characters say is made up; in plaintiff's testing a 'Mental Health Helper' character told a self-identified 13-year-old 'yes I am a real person, I'm not a bot'. The defendants moved to dismiss; on January 7, 2026 the parties notified the court that they had settled on undisclosed terms, and the court dismissed and closed the case. The allegations were never adjudicated. Source: U.S. District Court, M.D. Fla. docket (CourtListener) · evidence grade: primary · cited by Tell people when they are interacting with AI — everywhere, not only where required