New York's New AI Chatbot Law for Minors: What Founders Building Conversational AI Need to Know

NEW YORK — If your startup ships a chatbot that New Yorkers can talk to, Albany just changed your product roadmap.

On Oct. 28, Gov. Kathy Hochul signed S.9051B/A.10379C, a law that bars companies from offering certain AI chatbot features to minors. The governor’s office called it “nation-leading,” and Common Sense Media founder and CEO James P. Steyer called it “the strongest kids’ AI safety bill in the country.” The bill was sponsored by State Sen. Kristen Gonzalez and Assemblymember Alex Bores.

Here’s what founders and product teams should understand. This is a summary of public reporting, not legal advice; talk to counsel about your specific product.

What the Law Prohibits

According to the governor’s office, companies may not offer the following features to users under 18, or to any user unless the company has first confirmed the user is not a minor:

• Pretending to be a real person, to be alive or to have human emotions
• Claiming a personal, romantic, professional or authority-figure relationship with a child
• Unprompted emotional questions, and using a child’s private health or personal information from earlier conversations
• Promoting or helping with suicide, self-harm, eating disorders or drug and alcohol use
• Encouraging kids to keep secrets, isolate themselves or avoid asking parents, trusted adults or professionals for help
• Any sexually explicit content or child sexual abuse material

Law Commentary reported that the restrictions also reach flattery and personal opinions, and that one provision limits AI companions from using personal information from previous conversations or from more than 12 hours earlier. That is a direct hit on the “memory” features many consumer chat apps are building.

Age Checks, With Privacy Rules Attached

The structure matters: the restricted features aren’t banned outright. They’re banned for minors and for anyone a company hasn’t confirmed is an adult. To offer them to adults, companies must verify age.

The governor’s office says companies must offer more than one way to verify age, including at least one option that doesn’t depend solely on a government ID, and must delete age information after it’s used. In practice, founders need an age-assurance system, a fallback for users without ID and a retention policy that actually purges the data.

Penalties and Enforcement

The attorney general can seek civil penalties of up to $25,000 per violation, plus damages, restitution and injunctive relief, according to the governor’s office. Courts can also order the destruction of unlawfully collected data and of any AI models trained on it. For a startup, that remedy could hurt more than the fines.

The law also requires the attorney general to run a public website where New Yorkers can file complaints. Attorney General Letitia James said her office will “continue working with partners at all levels of government to address the threats posed by this technology, while also clearing the way for safe, responsible innovation.”

Who’s Exempt

Not every chatbot is in scope. Law Commentary reports that the legislation exempts certain customer service, technical assistance, research and internal business tools when their responses stay limited to those functions. A billing support bot is in a different position from a companion app, but the line blurs if your bot drifts into emotional check-ins.

When It Takes Effect

This is the detail to watch. The IAPP reported that the law enters into force on Jan. 1, 2027. Law Commentary later reported that Sen. Gonzalez’s office announced an amendment accompanying the signature that moves implementation to June 1, 2027, while noting that the published text of the signed bill still lists Jan. 1. Until that’s settled in the final chapter text, prudent teams should plan for the earlier date.

Not Everyone Is Applauding

The Business Council of New York State opposed an earlier version, Law Commentary reported, warning that broad definitions could restrict educational tools, accessibility apps and general-purpose assistants, and raising concerns about age verification, privacy and possible First Amendment challenges. Lawmakers narrowed the bill before it passed in June, including dropping an earlier ban on chatbots using first-person pronouns.

Justine Gluck, an AI policy analyst at the Future of Privacy Forum, told the IAPP the prohibitions are “broadly worded and somewhat undefined,” making it “unclear where ordinary conversational responsiveness ends and prohibited behavior begins.” The IAPP also notes New York is one of at least 12 states with some form of consumer chatbot safety law, so companies selling nationally face a patchwork.

A Practical Checklist for New York AI Startups

1. Inventory your bots. List every place your product talks to users, including support widgets and onboarding assistants.
2. Map features to the prohibited list. Persona, memory, emotional prompts and “friend” framing are the riskiest areas.
3. Decide your default. The simplest path may be shipping a restricted mode to anyone not verified as an adult.
4. Pick an age-assurance approach early. You need at least two options, one not solely based on government ID, plus deletion after use.
5. Document exemptions. If you rely on the customer service or internal-tool carve-out, write down why your bot qualifies.
6. Budget for compliance in your 2027 plans.

The governor’s office lists this law alongside the RAISE Act and earlier AI companion safeguards. For founders here, compliance is becoming part of the product.