NY, US · AI law tracker
A9106 — NY, US
A9106 is an AI governance legislation from NY, currently committee. This bill introduces patient consent requirements for AI use in recorded or transcribed therapy sessions [1]. AIGI tracks 1 primary-source update on this bill; the most recent was published on 2025-09-26.
Status & timeline
- Regulatory stage
- committee
- Bill status
- In Assembly Committee
- Authority / governing body
- New York State Senate
- Chamber
- Assembly
- Document type
- legislation
Next deadline: No fixed deadline — currently in committee
Subscriber only
Full obligation matrix
| Actor | Obligation | Deadline | Source |
|---|---|---|---|
| deployer | Inform patients of the specific purpose of artificial intelligence use when providing supplementary support in therapy or psychotherapy services where sessions are recorded or transcribed. | — | — |
| deployer | Obtain patient consent for the use of artificial intelligence to assist in providing supplementary support in therapy or psychotherapy services where sessions are recorded or transcribed. | — | — |
| deployer | Refrain from using artificial intelligence to assist in providing supplementary support where therapy sessions are recorded or transcribed unless the patient is informed and consents. | — | — |
Subscriber only
Enforcement risk score
Announced regulation; enforcement footprint still forming.
Subscriber only
Role-based compliance checklist
- general_counsel Monitor the progress of NY A9106 through the legislative process.
- compliance_officer Identify all existing or planned AI systems used for supplementary support in therapy or psychotherapy services, especially those involving recorded or transcribed sessions.
- compliance_officer Draft patient disclosure forms detailing the specific purposes of AI use in therapy services.
- compliance_officer Develop and implement a clear process for obtaining and documenting patient consent for AI use in therapy, as required.
- hr_director Prepare training materials and conduct staff training for all relevant personnel on the new disclosure and consent requirements.
Subscriber only
Vendor impact assessment
- Vendor risk class
- high
- Procurement categories
- healthcare_ai, productivity_assistants
Vendors providing AI solutions for therapy or psychotherapy services, particularly those that involve recording or transcribing sessions, will need to ensure their tools support client-side compliance with patient disclosure and consent requirements. This may involve specific features for consent management, data segregation, and transparent functionality.
Sample vendor questions
- How does your AI system process recorded or transcribed therapy sessions?
- What features or mechanisms does your system offer to help us obtain and document explicit patient consent for AI use, as required by law?
- Can your system facilitate the clear disclosure of specific AI purposes to patients?
- What data privacy and security measures are in place to protect patient information handled by your AI, especially sensitive therapy session data?
- How does your system differentiate between 'supplementary support' and core therapeutic functions, and what are its limitations in this context?
Intelligence briefs (1)
NY Bill A9106 Targets AI Use in Therapy and Psychotherapy Services
This bill introduces patient consent requirements for AI use in recorded or transcribed therapy sessions [1].
This signals emerging sector-specific AI deployer obligations concerning patient consent and transparency in healthcare.
Deadline: No fixed deadline — currently in committee
Primary source →Frequently asked questions
- What is A9106?
- New York Assembly Bill A9106 aims to regulate the use of artificial intelligence in therapy and psychotherapy services. It proposes prohibiting AI for supplementary support when sessions are recorded or transcribed, unless the patient is informed of the specific purpose and provides consent for such use [1]. The bill also outlines penalties for violations [2], while excluding religious counseling, peer-support, and self-help materials from its provisions. Primary source →
- Why does A9106 matter?
- This signals emerging sector-specific AI deployer obligations concerning patient consent and transparency in healthcare. Primary source →
- Who does A9106 affect?
- Organizations providing therapy or psychotherapy services within New York State are primarily affected. This includes entities utilizing AI for supplementary support, particularly when sessions are recorded or transcribed. The bill's scope specifically excludes religious counseling, peer-support activities, self-help materials, and educational resources from these provisions. Primary source →
- What are the key dates for A9106?
- No fixed deadline — currently in committee Primary source →
- What is the current status of A9106?
- As of the last published update, A9106 is at the "committee" stage, with bill status "In Assembly Committee". Primary source →
- Where can I find the primary source for A9106?
- The primary source for the most recent update is at https://legislation.nysenate.gov/bills/2025/A9106. AIGI publishes the full citation chain plus every approved brief on this bill. Primary source →
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