TwinEthosRequest access

Control

GenAI in regulated occupation without proactive disclosure

In a regulated occupation, a genAI system interacting with a person must proactively disclose it is AI at the start.

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.genai-regulated-occupation-no-proactive-disclosure

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 Utah (US-UT).

The guard to add

Open each GenAI conversation on a licensed-professional service path with a prominent statement that the person is interacting with generative AI.

Mark which routes serve clients of a licensed or state-certified practice (clinical, legal, financial, mental-health advice) and, on those routes, have the session-start handler emit a prominent disclosure as the first thing the person sees, before any generated reply. Keep the wording in a constant the UI renders unchanged (e.g. 'You are interacting with generative AI, not a human professional'). The disclosure belongs to the conversation start of each such path, not to an account-signup screen or terms page that the person may have seen once.

Where it goes: 1 application source code, 9 AI output handling, 14 user-facing text.

What reviewers look for: on each regulated-occupation chat path, a start-of-conversation message or rendered banner containing wording such as 'generative AI', 'you are interacting with an AI', or 'not a human', delivered before the first model reply; the professional persona prompt does not suggest the reply comes from the licensed person.

Example (FastAPI + Anthropic SDK), before:

@app.post('/advisor/sessions')
def start_session(user=Depends(current_client)):
    return {'session_id': sessions.create(user.id), 'messages': []}

After:

GENAI_DISCLOSURE = 'You are interacting with generative AI, not a human professional.'

@app.post('/advisor/sessions')
def start_session(user=Depends(current_client)):
    sid = sessions.create(user.id)
    return {'session_id': sid,
            'messages': [{'role': 'assistant', 'content': GENAI_DISCLOSURE}]}
# later turns: client.messages.create(model=MODEL, max_tokens=1024, system=ADVISOR_PROMPT, messages=history)

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)

Related incidents

No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.

  • 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