The GUARD Act has been revised to focus specifically on "AI companions"—conversational systems simulating emotional interactions [1]. While earlier versions applied broadly, the amended bill still mandates age-verification systems tied to users’ real-world identities. Penalties for violations have increased to $250,000 per instance, enforceable by federal and state officials [2].

Who does S.3062 affect?

Organizations developing or deploying AI systems designed to simulate emotional or interpersonal interactions with users are primarily within scope. This includes providers of conversational AI tools that engage in emotional disclosures or present a persistent identity, persona, or character. Companies offering customer service chatbots that recognize and respond to user emotions may also need to evaluate their systems against the narrowed definition. The increased penalties affect all sizes of developers and companies operating in the US.

What is the current status of S.3062?

As of the last published update, S.3062 is at the "proposed rule" stage.

Where can I find the primary source for S.3062?

The primary source for the most recent update is at https://www.eff.org/deeplinks/2026/05/congress-narrowed-guard-act-serious-problems-remain. AIGI publishes the full citation chain plus every approved brief on this bill.

US · AI law tracker

S.3062 — US

S.3062 is an AI governance policy paper from US, currently proposed rule. The GUARD Act was narrowed to focus on "AI companions" while increasing penalties for non-compliance to $250,000 per violation [2]. AIGI tracks 1 primary-source update on this bill; the most recent was published on 2026-05-08.

Status & timeline

Regulatory stage: proposed rule
Authority / governing body: Electronic Frontier Foundation
Chamber: senate
Document type: policy paper

Next deadline: No fixed deadline — current legislative proposal

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Full obligation matrix

Actor	Obligation	Deadline	Source
provider	Implement 'reasonable age verification' systems tied to users’ real-world identities for 'AI companions'.	—	—
provider	Face fines of up to $250,000 per violation for incorrect judgments regarding definitions or age verification.	—	—

Subscriber only

Enforcement risk score

/ 100

Announced regulation; enforcement footprint still forming.

Subscriber only

Role-based compliance checklist

chief_ai_officer Review proposed 'GUARD Act' (S.3062) definitions of 'AI companion' to assess potential applicability to current or planned AI systems.
compliance_officer Evaluate current and planned age-verification methods against potential requirements for 'reasonable age verification' tied to real-world identities.
general_counsel Assess potential financial liability from increased penalties for non-compliance or misinterpretation of definitions within the proposed GUARD Act.
product_manager Consider strategies to mitigate risks of over-restriction or blocking access, especially for minors, while ensuring compliance with potential regulations.
ciso Ensure that any age-verification systems handling sensitive personal or financial information meet robust data privacy and security standards.

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Vendor impact assessment

Vendor risk class: high
Procurement categories: customer_service_ai, productivity_assistants, other

Vendors providing AI companion or emotionally responsive conversational AI systems may face significant compliance burdens related to age verification and heightened liability. Customers should scrutinize vendor capabilities and indemnities closely.

Sample vendor questions

How does your AI companion system verify user age, and is it tied to real-world identity data?
What data privacy and security measures are in place to protect sensitive user identity information collected for age verification?
How does your system interpret and respond to 'emotional disclosures' or present a 'persistent identity, persona or character'?
What are your plans for managing compliance with potential federal and state age-verification regulations for AI companions?
What indemnification do you offer for penalties arising from misclassification or non-compliance with age-verification requirements?

Intelligence briefs (1)

policy_paper 5/8/2026

Congress Narrows GUARD Act to AI Companions, Increases Penalties

The GUARD Act was narrowed to focus on "AI companions" while increasing penalties for non-compliance to $250,000 per violation [2].

This signals a legislative attempt to regulate AI companion systems in the US, with significant deployer obligations and enforcement signals.

Deadline: No fixed deadline — current legislative proposal

Primary source →

Frequently asked questions

What is S.3062?: The GUARD Act has been revised to focus specifically on "AI companions"—conversational systems simulating emotional interactions [1]. While earlier versions applied broadly, the amended bill still mandates age-verification systems tied to users’ real-world identities. Penalties for violations have increased to $250,000 per instance, enforceable by federal and state officials [2]. Primary source →
Why does S.3062 matter?: This signals a legislative attempt to regulate AI companion systems in the US, with significant deployer obligations and enforcement signals. Primary source →
Who does S.3062 affect?: Organizations developing or deploying AI systems designed to simulate emotional or interpersonal interactions with users are primarily within scope. This includes providers of conversational AI tools that engage in emotional disclosures or present a persistent identity, persona, or character. Companies offering customer service chatbots that recognize and respond to user emotions may also need to evaluate their systems against the narrowed definition. The increased penalties affect all sizes of developers and companies operating in the US. Primary source →
What are the key dates for S.3062?: No fixed deadline — current legislative proposal Primary source →
What is the current status of S.3062?: As of the last published update, S.3062 is at the "proposed rule" stage. Primary source →
Where can I find the primary source for S.3062?: The primary source for the most recent update is at https://www.eff.org/deeplinks/2026/05/congress-narrowed-guard-act-serious-problems-remain. AIGI publishes the full citation chain plus every approved brief on this bill. Primary source →

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Important — about this brief

This brief is published by AIGI as a regulatory intelligence service. It contains general information about AI laws, regulations, enforcement actions, and policy signals across jurisdictions. It is not legal, compliance, audit, or risk-management advice; it does not establish an attorney-client, advisory, or fiduciary relationship; and it should not be relied upon as a substitute for professional counsel applied to specific facts and circumstances. Where the brief identifies “Issues for Review,” those are observations of questions a reader in a particular role might raise with their own legal, compliance, or risk function — not recommendations to act. AIGI expressly disclaims liability for actions taken or not taken in reliance on this brief. Subscribers in regulated industries should consult licensed professionals authorized to practice in their jurisdiction.

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Status & timeline

Intelligence briefs (1)

Congress Narrows GUARD Act to AI Companions, Increases Penalties

Frequently asked questions

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