IA, US · AI law tracker
HF 2204 — IA, US
HF 2204 is an AI governance legislation from IA, currently introduced. House File 2204 introduces new obligations for chatbot deployers concerning harm mitigation, data collection, age verification, and impersonation [1], [2]. AIGI tracks 1 primary-source update on this bill; the most recent was published on 2026-01-29.
Status & timeline
- Regulatory stage
- introduced
- Bill status
- introduced
- Authority / governing body
- Iowa Legislature
- Chamber
- house
- Document type
- legislation
Next deadline: No fixed deadline — proposed legislation.
Subscriber only
Full obligation matrix
| Actor | Obligation | Deadline | Source |
|---|---|---|---|
| deployer | Implement and maintain protocols to detect, respond to, report, and mitigate harm the chatbot may cause a user, prioritizing user safety and well-being. | — | — |
| deployer | Limit the collection and storage of user information collected by the chatbot to what is necessary for the deployer’s purpose of making the chatbot publicly available. | — | — |
| deployer | Implement reasonable age verification measures to ensure a minor cannot use or purchase an AI companion made publicly available. | — | — |
| deployer | Obtain permission from a living individual or their legal representative before making a chatbot publicly available that was knowingly designed to impersonate that individual. | — | — |
| deployer | Obtain permission from the person responsible for a deceased individual’s estate before making a chatbot publicly available that was knowingly designed to impersonate that individual (unless designed solely as an educational/research tool or having objective artistic/cultural/political value). | — | — |
| deployer | Provide a clear and conspicuous disclaimer at the beginning of each interaction with a therapeutic chatbot, stating it is an artificial intelligence and not a licensed professional, before making it available for a minor's use. | — | — |
| deployer | Ensure a therapeutic chatbot was recommended for a minor's use by an individual licensed under chapter 154B or 154D after an evaluation of the minor, before making it available for a minor's use. | — | — |
| developer | Possess significant documentation of how the therapeutic chatbot was tested, for it to be made available for a minor's use. | — | — |
| developer | Ensure peer-reviewed clinical trial data exists demonstrating the therapeutic chatbot is a safe and effective tool for a minor’s diagnosis, treatment, mitigation, or prevention of a mental health condition, for it to be made available for a minor's use. | — | — |
| deployer | Provide clear disclosures of a therapeutic chatbot’s functions, limitations, and data privacy policies to the recommending professional and the minor’s parents, guardians, or custodians, before making it available for a minor's use. | — | — |
| deployer | Develop and implement protocols for testing a therapeutic chatbot for risks to users, identifying possible risks, mitigating risks, and quickly rectifying harm, before making it available for a minor's use. | — | — |
Subscriber only
Enforcement risk score
25
/ 100
Announced regulation; enforcement footprint still forming.
Subscriber only
Role-based compliance checklist
- compliance_officer Review existing chatbot deployment protocols for alignment with harm detection, response, reporting, and mitigation requirements, prioritizing user safety.
- data_scientist Assess current user information collection and storage practices for chatbots to ensure data is limited to what is necessary for the chatbot's public purpose.
- product_manager Implement reasonable age verification measures for any AI companions to prevent use or purchase by minors.
- legal Establish a process for obtaining explicit permission before deploying chatbots designed to impersonate living or deceased individuals.
- compliance_officer Develop and implement a clear and conspicuous disclaimer for therapeutic chatbots stating their AI nature and lack of professional licensing, to be shown at the start of each interaction with minors.
- product_manager Ensure therapeutic chatbots for minors are only available upon recommendation by a licensed professional following a minor's evaluation.
- engineering Ensure robust documentation of therapeutic chatbot testing and verification of peer-reviewed clinical trial data for safety and effectiveness, especially if targeting minors.
- legal Prepare clear disclosures of therapeutic chatbot functions, limitations, and data privacy policies for licensed professionals and parents/guardians of minors.
- risk_manager Develop and implement specific protocols for therapeutic chatbots to test for, identify, mitigate, and rectify user risks, particularly for minor users.
Subscriber only
Vendor impact assessment
- Vendor risk class
- high
- Procurement categories
- customer_service_ai, healthcare_ai, content_moderation, other
Vendors providing public-facing chatbots, especially AI companions or therapeutic chatbots, will face significant scrutiny regarding harm mitigation, data privacy, age verification, and consent for impersonation. Providers of therapeutic chatbots for minors must demonstrate robust testing, clinical efficacy, and comprehensive disclosure mechanisms.
Sample vendor questions
- What protocols do you have in place for detecting, responding to, reporting, and mitigating harm caused by your chatbot to users, prioritizing user safety?
- How do you limit the collection and storage of user information to what is strictly necessary for the chatbot's intended purpose?
- What age verification measures are implemented for AI companions, particularly to prevent access by minors?
- What is your policy and process for ensuring your chatbot does not impersonate real individuals without explicit permission?
- For therapeutic chatbots, can you provide documentation of testing, peer-reviewed clinical trial data for safety and effectiveness, and details on how you ensure disclosures are made to professionals and parents?
- How does your chatbot ensure a clear and conspicuous disclaimer is presented at the start of each interaction, stating its AI nature and lack of professional licensing, especially for minors?
Intelligence briefs (1)
legislation introduced 1/29/2026
Iowa HF 2204: New Chatbot Deployer Obligations & Minor Protections
House File 2204 introduces new obligations for chatbot deployers concerning harm mitigation, data collection, age verification, and impersonation [1], [2].
This legislation establishes specific deployer obligations for AI companions and therapeutic chatbots, signaling state-level AI product safety requirements.
Deadline: No fixed deadline — proposed legislation.
Primary source →Frequently asked questions
- What is HF 2204?
- Iowa House File 2204 introduces specific requirements for chatbot deployers, including protocols for detecting and mitigating harm, and limitations on user information collection [1]. The bill mandates reasonable age verification for AI companions to prevent minor access and restricts chatbots from knowingly impersonating individuals without consent [2]. Specialized conditions are established for therapeutic chatbots intended for use by minors [2]. Primary source →
- Why does HF 2204 matter?
- This legislation establishes specific deployer obligations for AI companions and therapeutic chatbots, signaling state-level AI product safety requirements. Primary source →
- Who does HF 2204 affect?
- This bill primarily impacts deployers of publicly available chatbots, particularly those classified as 'AI companions' or 'therapeutic chatbots' intended for interaction with individuals under eighteen years of age. Organizations providing services that simulate human-like romantic or emotional bonds, or offer mental health support through AI, within Iowa’s jurisdiction are directly within scope. Considerations extend to deployers of generative AI applications capable of human conversation or content generation. Primary source →
- What are the key dates for HF 2204?
- No fixed deadline — proposed legislation. Primary source →
- What is the current status of HF 2204?
- As of the last published update, HF 2204 is at the "introduced" stage, with bill status "introduced". Primary source →
- Where can I find the primary source for HF 2204?
- The primary source for the most recent update is at https://www.legis.iowa.gov/publications/search/document?fq=id:1596673&q=artificial+intelligence. AIGI publishes the full citation chain plus every approved brief on this bill. Primary source →
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