Oregon's SB 1546 and Washington's HB 2225, both effective January 1, 2027, target AI "companion" chatbots built to simulate friendship or romance — not the software that answers a business phone. Oregon excludes customer-service tools by purpose alone, no matter how natural they sound. Washington's exclusion is narrower: it only holds if the system doesn't sustain a relationship or generate emotionally engaging responses.
Two new Northwest laws, and one of them has real financial teeth
Oregon's governor signed SB 1546 on March 31, 2026; it becomes Chapter 85 of Oregon Laws 2026 and takes effect January 1, 2027. It's not a soft rule — anyone who suffers a loss because of a violation can sue for the greater of actual damages or $1,000 in statutory damages per violation, plus attorney fees and an injunction (Oregon Legislature, 2026). Washington's HB 2225 covers similar ground but enforces differently: a violation is treated as an unfair or deceptive act under the state's existing Consumer Protection Act, not a new standalone penalty (Washington State Legislature, 2026). Both laws exist for the same reason — a wave of AI "companion" apps marketed as friends, therapists, or romantic partners, some aimed at teenagers — not for the phone system that books a plumbing appointment.
Oregon draws the line by purpose, not by how human the bot sounds
Oregon's law defines an "artificial intelligence companion" as a system designed to simulate a sustained, human-like relationship by retaining personal information to build ongoing engagement, asking unprompted emotional questions, and sustaining dialogue about matters personal to the user — all three together, not just one. Then it excludes, in its own words: "software that operates solely for the purpose of customer service or support... business operations, productivity, information analysis, internal research or technical assistance, regardless of the software's capability to use natural language inputs and generate natural language outputs" (Oregon Legislature, 2026). That last clause is doing the real work. It means a natural-sounding AI receptionist that books jobs and answers pricing questions doesn't get closer to the line by sounding warm or conversational — the test is what the software is for, not how convincingly it talks.
Washington's exclusion carries a condition Oregon's doesn't
Washington's HB 2225 excludes "a bot that is used only for a business' operational purposes, productivity and analysis related to source information, internal research, technical assistance, or customer service, if such bot does not sustain a relationship across multiple interactions and generate outputs that are likely to elicit emotional responses in the user" (Washington State Legislature, 2026). Read the second half of that sentence again — Oregon's carve-out is unconditional once the purpose is customer service; Washington's is conditional on the bot's actual behavior. A system that remembers a returning caller's name isn't automatically disqualified, but a system built to keep someone emotionally engaged across calls is exactly the combination the Washington exclusion withholds itself from.
| Oregon (SB 1546) | Washington (HB 2225) | |
|---|---|---|
| Effective date | Jan 1, 2027 | Jan 1, 2027 |
| Exclusion test | Purpose-based — customer service software is excluded outright | Conditional — excluded only if it doesn't sustain a relationship or elicit emotional responses |
| Enforcement | Private right of action; $1,000/violation or actual damages, plus attorney fees | State Consumer Protection Act — unfair or deceptive trade practice |
| Who actually needs to worry | Products built to simulate companionship or romance | Any bot that layers relationship-building or emotional engagement onto a business tool |
Not a hypothetical for the Portland metro specifically
The Columbia River splits Vancouver, Washington from Portland, Oregon — one metro area, two states. Plenty of home-service and professional-service businesses in that market serve customers, and sometimes run offices, on both sides of the river. The same AI phone system answering calls for that business could, in practice, sit under two different legal tests depending on which side of the river a call — or the company's own registration — falls on. Knowing that Washington's test is the stricter one to design around matters more there than almost anywhere else in the Northwest.
- A system that answers calls, books jobs, and quotes pricing sits comfortably inside both exclusions, even if it sounds completely natural.
- The actual risk isn't "AI that sounds human" — it's a feature set built to keep someone emotionally engaged: unprompted check-ins unrelated to the business, simulated memory of someone's life outside the transaction, or design meant to keep a caller coming back to talk.
- Operating in both Oregon and Washington means designing to Washington's conditional test, the stricter of the two — Oregon's purpose-based exclusion is closer to a blanket safe harbor for genuine business software.
- Ask any AI phone vendor directly what the system retains about a caller between calls, and why — that answer is what would actually matter under either law.
Montana, for comparison, has no AI companion or AI phone-disclosure law on the books at all as of 2026 — its Consumer Data Privacy Act reaches AI used in "consequential decisions" like credit or pricing, not a general conversational phone system (ai-law-tracker.com, 2026). For a Kalispell or Missoula business, this entire question doesn't come up yet; for one in Portland or Vancouver, it already has an answer.