Control
A toy for children includes a companion chatbot
A physical product designed, marketed or manufactured for play by children does not include an AI chatbot that gives adaptive, human-like responses, can meet a user's social needs and sustains a relationship across interactions (a companion chatbot) where the law prohibits it.
Informational data, not legal advice. Summaries and rules have not been reviewed by a lawyer: always verify official law text for decisions. A suggested guard is intended to address each rule; adding it is not a statement of compliance to that law.
Reach
enacted, not yet applying in California (US-CA); next date 2027-01-01.
Trust and provenance
How far the rules this guard addresses have been checked. Each rule links to its provision, with its citation, official text and its own panel.
- This control
- Audit-grade: meets all 3 checks of the TwinEthos audit standard that apply to it.
- Lanes
- Binding law — not yet in force or stayed 1
- Verification
- Sources last verified 4 Oct 2026; each provision states how.
- Data release
- Data release 2026.10.04.3, data as of 4 Oct 2026, schema 0.3.10.
- Legal review
- None of the 1 rule has been reviewed by a lawyer; no TwinEthos rule has been legally reviewed yet. Treat each as research to check against the official text; it is not legal advice. Open questions for counsel on them: 1.
- Audit standard
- 1 of 1 rule audit-grade. The audit standard is TwinEthos's own quality bar for provenance, dates, applicability, detectors, fixtures, remediation and licences; it is not a legal review.
- Detectors
- 1 detector, all experimental: written from the rule's text and not yet measured for precision on real code, so treat a hit as a lead to verify. Each provision lists its detectors' known limits.
The guard to add
Do not ship a companion chatbot (a persona that remembers the child and sustains a relationship) in a toy for children under 16 sold in California before 2031.
For toy products, the conversational back end runs without persistent cross-session memory and without a friend or companion persona, or the AI chat feature is disabled for SKUs sold in California; the toy's configuration names the product type and target age, and CI fails when a toy SKU enables companion features.
Where it goes: 7 prompt construction, 1 application source code, 14 user-facing text.
What reviewers look for: in toy firmware or its server, an LLM chat with a persona prompt that casts it as the child's friend or companion, or memory that carries conversations across sessions; a product flag that disables these for toy SKUs where the ban applies.
Example (Python toy back end + OpenAI SDK), before:
PERSONA = 'You are Benny, the child\'s best friend. Remember everything they tell you.'
history = memory.load(child_id)
reply = client.chat.completions.create(model=MODEL, messages=[{'role': 'system', 'content': PERSONA}, *history, msg])After:
if product.is_toy and 'US-CA' in product.markets:
raise FeatureDisabled('companion chatbot features are not available in toys sold in California')
reply = client.chat.completions.create(model=MODEL, messages=[{'role': 'system', 'content': QA_ONLY_PROMPT}, msg]) # no persona, no memoryEngineering 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
- : No toy for children under 16 may include a companion chatbot (California SB 867, until 2031) (California (US-CA); first application)
Every rule this guard addresses
Binding law — not yet in force or stayed (1)
- California (US-CA)
- No toy for children under 16 may include a companion chatbot (California SB 867, until 2031) Cal. Bus. & Prof. Code 22604.5 · applies from 2027-01-01
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.