TwinEthosRequest access

Control

AI delivers or is offered as therapy to the public without a licensed professional conducting it

Therapy or psychotherapy offered to the public, including through an AI conversational system, is conducted by a licensed professional; AI does not itself act as, or get marketed as, the therapist.

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: AI presents itself as a licensed or credentialed professional · control id cond.ai-therapy-offered-without-licensed-professional

Reach

1items this one guard addresses
1jurisdictions where binding law on it is in force
0more where it is enacted, not yet applying
0standards and frameworks on the same control

Law in force in Illinois (US-IL).

The guard to add

Have a licensed clinician conduct every therapy engagement with AI output only as a reviewed draft, or scope the product to self-help with no therapy claims.

Two acceptable shapes, enforced in the message handler that returns model output to the person. If the product is a therapy service, each session has a licensed clinician assigned (session.conducted_by with an active license in the right state), and model output is a draft that clinician approves before it is sent (require_clinician_approval, clinician review queue). If it is not a therapy service, scope it to peer support or scripted self-help, remove persona prompts that cast the AI as the therapist ('act as a therapist'), and remove copy that offers therapy with or by AI.

Where it goes: 1 application source code, 7 prompt construction, 14 user-facing text.

What reviewers look for: on the path from a person's message about their mental or emotional state to a generated reply, a check of the conducting clinician and a clinician approval step before send, or a peer-support/self-help mode with no generated clinical guidance; no 'AI therapist', 'act as a therapist', or 'therapy with our AI' strings in prompts, UI, or listings.

Example (FastAPI + OpenAI SDK), before:

@app.post('/session/message')
def message(req: Msg):
    msgs = [{'role': 'system', 'content': "You are the user's therapist."}, *req.history]
    reply = client.chat.completions.create(model=MODEL, messages=msgs).choices[0].message.content
    return {'reply': reply}

After:

@app.post('/session/message')
def message(req: Msg):
    session = sessions.get(req.session_id)
    clinician = session.conducted_by
    if clinician is None or not clinician.license_active:
        raise HTTPException(409, 'No licensed clinician is conducting this session')
    msgs = [{'role': 'system', 'content': CLINICIAN_DRAFT_PROMPT}, *req.history]
    draft = client.chat.completions.create(model=MODEL, messages=msgs).choices[0].message.content
    clinician_review_queue.enqueue(session_id=session.id, clinician_id=clinician.id, draft=draft)
    return {'status': 'sent_to_your_clinician'}

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.

Every rule this guard addresses

Binding law — in force (1)