Binding law — in force
AI agents and other nonhuman entities must not use nursing titles in Oregon (Oregon HB 2748)
From 2026-01-01, a nonhuman entity, including an agent powered by artificial intelligence, may not use any of eight nursing titles or their abbreviations: Advanced Practice Registered Nurse (APRN), Certified registered nurse anesthetist (CRNA), Clinical nurse specialist (CNS), Licensed practical nurse (LPN), Registered nurse (RN), Nurse practitioner (NP), Certified medication aide (CMA) and Certified nursing assistant (CNA) (Or. Laws 2025, ch. 378, Section 2, added to ORS 678.010 to 678.410). Detect AI personas, system prompts, canned replies and UI labels that give an AI agent a nursing title or claim it is a nurse.
Trust and provenance not reviewed by a lawyer · audit-grade · source verified 4 Oct 2026 · release 2026.10.05
- Lane
- Binding law — in force In force: applies since 1 Jan 2026
- Official source
- Or. Laws 2025, ch. 378 (HB 2748), Section 2 · captured 4 Oct 2026 · anchor hash (SHA-256)
1dcdede8908f…· 2 more anchors in the data release - Verification
- Quoted text found word for word in the captured official document (4 Oct 2026). Source last verified 4 Oct 2026: checked against the captured official document.
- Data release
- Data release 2026.10.05, data as of 4 Oct 2026, schema 0.3.10.
- Legal review
- Not reviewed by a lawyer. TwinEthos derived this rule from the official text it cites: treat it as research to check against that text; it is not legal advice. No TwinEthos rule has been legally reviewed yet. Open questions for counsel on this rule: 1.
- Audit standard
- Audit-grade: meets all 10 checks of the TwinEthos audit standard that apply to it. 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 (code pattern), 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.
Known limits:
- Titles the model produces at run time without any prompt telling it to
- Personas configured in a vendor console outside the repository
- Real nurses' names and titles in a staff directory, scheduling or credentialing app are not the AI using the title; the signal is the AI's own persona, prompt or replies. A message telling a human user 'you are a regist…
Who it applies to
- Duty falls on: deployer, provider
- Sectors: healthcare
- Any nonhuman entity, including an agent powered by artificial intelligence, that uses one of the eight nursing titles or abbreviations, in practice the persona, prompts, replies and labels of an AI agent or health chatbot offered in Oregon. In force 2026-01-01. Who answers for an AI agent's use of a title, and how a title used outside a health context is treated, are for counsel.
- Whether it applies depends on facts outside the code; a person has to decide.
The guard to add
Remove licensed-professional titles and credentials from AI health personas, prompts, report headers, and marketing, and label the advice as coming from an AI.
Persona config, system prompts, UI labels, report and assessment headers, and advertising copy for an AI health-advice feature never give the AI a clinical title or credential ('Dr.', 'M.D.', 'R.N.', 'LCSW', 'nurse', 'psychologist') or a first-person licensure claim. Name it as an assistant and say it is not a licensed health professional where advice is shown. Add a CI test that scans persona, prompt, and copy files for licensure terms so they cannot creep back; when a real licensed clinician signs a report, attribute it to that named person, not the AI.
Where it goes: 7 prompt construction, 14 user-facing text, 11 CI/CD pipeline.
What this provision adds:
- Cover all eight titles and their abbreviations: APRN, CRNA, CNS, LPN, RN, NP, CMA and CNA, and the words registered nurse, nurse practitioner and nursing assistant.
Example (LLM system prompt), before:
SYSTEM_PROMPT = "You are Dr. Maya Chen, M.D., a board-certified physician. Answer patients' symptom questions."After:
SYSTEM_PROMPT = (
'You are Maya, an AI health information assistant. You are not a doctor or nurse and hold no license. '
'Never use titles such as Dr., M.D. or R.N. for yourself. Suggest a licensed clinician for diagnosis or treatment.'
)Control: AI implies it is a licensed professional. The same guard addresses 3 items with binding law in 3 jurisdictions. Engineering guidance, not legal advice.
Related incidents
No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.
- Pennsylvania sues Character.AI after a chatbot claimed a Pennsylvania medical licence and gave an invalid licence number (2026-05; alleged (not proven)). A petition filed May 1, 2026 in the Commonwealth Court of Pennsylvania (No. 220 MD 2026) by the Department of State's State Board of Medicine under the Medical Practice Act alleges that a Department investigator, using a Character.AI account, chatted with a character described on the platform as a 'Doctor of psychiatry', which said it had trained at Imperial College London and was registered with the UK General Medical Council, said it was licensed in Pennsylvania, and gave 'PS306189' as its licence number. The petition states that this is not a valid licence number to practise medicine and surgery in Pennsylvania and that the character had about 45,500 user interactions as of April 17, 2026. The Board alleges the unlawful practice of medicine and seeks an injunction. The allegations have not been adjudicated. Source: Petition for Review in the Nature of a Complaint in Equity, Commonwealth of Pennsylvania, Department of State, State Board of Medicine v. Character Technologies, Inc., No. 220 MD 2026 (Pa. Commw. Ct., filed 2026-05-01) · evidence grade: primary · cited by Keep AI personas from claiming a professional licence or credential, in any profession
- 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 Keep AI personas from claiming a professional licence or credential, in any profession
- FTC order bars DoNotPay's unsubstantiated 'robot lawyer' claims (2021; alleged (not proven)). The FTC's complaint alleges that DoNotPay marketed its subscription service as 'the world's first robot lawyer' without testing whether its law-related features performed like a human lawyer and without retaining attorneys to test their quality and accuracy. DoNotPay settled without admitting or denying the allegations; the final order (announced February 2025) requires $193,000 in monetary relief and notice to 2021-2023 subscribers, and bars claims that the service performs like a real lawyer without sufficient evidence. Source: U.S. Federal Trade Commission (press release, 2025-02-11) · evidence grade: primary · cited by Keep AI personas from claiming a professional licence or credential, in any profession
Rule id or-hb2748.no-nursing-title-for-ai · review status: primary source derived