This page covers U.S. law as of June 2026. This is not legal advice. For a plain-English compliance answer tailored to your situation, use the Compliance Checker at DiscloseAI.net.
In Utah, yes — disclosure is legally required for regulated businesses. Under FTC deception doctrine, failing to disclose that a chatbot is AI when consumers would reasonably believe they are speaking with a human is likely deceptive in any state. Best practice is to disclose at the start of every AI chat interaction.
Utah — Explicit Legal Requirement
Utah's Artificial Intelligence Policy Act (SB 149, effective May 1, 2024) is the most direct state law on this question. It requires entities in regulated occupations — healthcare, financial services, legal services, real estate, and others — to disclose when a consumer is interacting with an AI system rather than a human. Representing that an AI system is a human is prohibited. Utah Code Ann. § 13-2-15 et seq.
FTC Standard — Applies in Every State
Even in states without an explicit chatbot disclosure law, the FTC's deception standard applies. A reasonable consumer interacting with a business through a text-based chat interface will often assume they are speaking with a human customer service representative. If that assumption is incorrect, and the distinction is material to the consumer, the failure to disclose is likely deceptive under FTC Act Section 5.
The FTC has taken enforcement actions against businesses that deployed automated systems in ways that deceived consumers into thinking they were speaking with humans. The FTC's updated guidance makes clear that AI chatbots must not be designed to create the impression of human interaction when none exists.
California BOT Disclosure Act
California enacted the Bolstering Online Transparency (BOT Disclosure) Act (Cal. Bus. & Prof. Code § 17940 et seq.), effective July 1, 2019. The law prohibits using bots to communicate with Californians online with the intent to mislead them about the bot's artificial identity. The law applies to bots used to influence purchases, voting, or opinion, establishing the principle that bots must not deceive consumers about their artificial nature.
Implementation Checklist
- Identify your chatbot as an AI assistant in the first message of every conversation
- Do not give your AI chatbot a human name without clear AI identification
- Provide a clear path to a human representative for consumers who request one
- If you operate in Utah or serve Utah customers in a regulated occupation, ensure compliance with SB 149
- If you are in a regulated industry (healthcare, financial services, legal, real estate) in any state, treat Utah's standard as your national baseline
- Review chatbot conversation logs periodically to confirm the AI is not creating a deceptive impression of human operation