Utah AI Policy Act (Ch. 77)

Binding law — in force

GenAI in a consumer transaction must disclose on a consumer's clear request

Utah Code 13-77-103(1) · official text · In force: applies since 7 May 2025 · Utah (US-UT)

A supplier using generative AI to interact with a consumer in a consumer transaction must disclose that the consumer is interacting with genAI (not a human) when the consumer clearly and unambiguously asks. Detect a consumer-facing genAI path with no mechanism to answer an AI-identity request. (A safe harbor exists for always-on disclosure at the outset and throughout.)

Who it applies to

• Duty falls on: deployer
• Suppliers using genAI in consumer transactions with Utah consumers. Reactive duty: disclosure required on a clear/unambiguous consumer request. Effective 2025-05-07.

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

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

Standards that recommend the same control

• Persons should be notified they are interacting with an AI system (CoE Framework Convention) (CoE AI Framework Convention (CETS 225) · CoE Framework Convention on AI (CETS 225), Article 15(2))
• AI should be transparent, traceable, and disclose AI interaction to users (EU ALTAI) (EU ALTAI · ALTAI / EU Ethics Guidelines — Requirement 4 (Transparency))
• AI operators should provide verifiable transparency information and maintain accountability (Japan) (Japan AI Guidelines for Business · Japan AI Guidelines for Business Ver1.1 (MIC/METI) — Common Guiding Principles 6) Transparency and 7) Accountability)
• People should be made aware they are interacting with AI (OECD AI Principles · OECD/LEGAL/0449 — Principle 1.3)

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

Rule id ut-ai-policy-act.genai-consumer-transaction-disclosure · review status: primary source derived

Binding law — in force

GenAI in a regulated occupation must proactively disclose it is AI in high-risk interactions

Utah Code 13-77-103(2)-(3) · official text · In force: applies since 7 May 2025 · Utah (US-UT)

An individual providing regulated-occupation services (licensed/state-certified) must prominently disclose, at the start of the interaction, that the person is interacting with generative AI — but only where the use is a 'high-risk AI interaction' (sensitive data like health/financial/biometric, or advice on financial/legal/medical/mental-health matters). Detect genAI on a regulated-occupation high-risk path without a start-of-interaction disclosure.

Who it applies to

• Duty falls on: deployer, individual professional
• Sectors: healthcare, essential services
• Individuals in Utah regulated occupations (requiring a license/state certification) using genAI in high-risk interactions (sensitive data or significant personal-decision advice). Effective 2025-05-07 (amended 2026).
• Whether it applies depends on facts outside the code; a person has to decide.

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

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)

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

Rule id ut-ai-policy-act.genai-regulated-occupation-disclosure · review status: primary source derived