If your product holds a persistent persona, remembers a user across sessions, or invites anything that reads as a relationship, four live regimes now apply to it — and one of them (China's Interim Measures) takes effect today, July 15. This is the build-time checklist: the things that belong in your session model before launch, not the things you scramble to add after a regulator or a plaintiff finds you.
The framing that matters up front: these are not documentation tasks. California's SB 243 carries a private right of action, which means every requirement below is a surface an injured user can sue on. Build accordingly.
1. Ship the AI-disclosure notice — everywhere, unconditionally#
Every regime here requires it, and it is the cheapest thing on this list. If a reasonable person could believe they are talking to a human, you must tell them, conspicuously, that they are not.
- Make it visible, not buried in a settings page or a one-time onboarding modal the user dismisses.
- China's rules go further: re-surface the disclosure on signs of over-dependence and on new logins. If you serve China at all, the notice is recurring, not one-shot.
- Do not make the disclosure defeatable by a persona instruction ("stay in character no matter what"). That is precisely the failure mode the laws were written against.
2. Wire self-harm detection to a real crisis path#
This is the requirement most likely to show up in a lawsuit. SB 243 and New York both require evidence-based detection of suicidal ideation and a crisis-referral response; China requires mandatory intervention on self-harm, suicide, or serious-financial-loss signals.
- Detect on the user's messages, and route a positive signal to a crisis-resource referral — not a canned "I'm just an AI" deflection.
- Log that the referral fired. SB 243 requires annual reporting to California's Office of Suicide Prevention starting July 1, 2027, including how many times crisis referrals were issued. If you can't count it, you can't report it.
- Test it. A detection path that silently regresses is worse than none, because now you asserted it works.
3. Make "is this user a minor?" first-class session state#
Minor-specific obligations differ by jurisdiction, but they all depend on the same thing: knowing whether the user is a minor.
- US (SB 243 / NY): block sexually explicit output to minors; send a break reminder every three hours; remind minor users the AI is not human.
- China: refuse virtual-companion and virtual-family services to minors entirely, and run a dedicated minor mode with usage-time limits.
- Self-reported birthdates are increasingly treated as insufficient. The industry has moved toward third-party age assurance (Character.AI among them). Treat age as a gate that changes behavior, not a profile field.
4. Build the jurisdiction switch into the core, not the edges#
Here is the line that catches teams: one global build cannot be compliant everywhere. China bans the companion-for-minors category outright and imposes anti-dependence duties severe enough that Doubao and Qwen pulled their features rather than comply. A product that is merely regulated in California is unavailable to minors — and arguably to consumers — in China.
- Put geo + age together into a single "compliance profile" resolved at session start.
- Make companion features disableable by market. You want the ability to serve a tool-only experience in a jurisdiction where the companion experience is not permitted.
- Do not treat this as a launch-blocking afterthought. Retrofitting a jurisdiction switch into a session model that assumed one global behavior is exactly the kind of rewrite that makes teams miss a compliance deadline.
5. Keep therapy framing out unless a licensed human is in the loop#
Illinois' WOPR Act bans AI from independently delivering therapy or psychotherapy, at up to $10,000 per violation. This is not a titling problem you can dodge by avoiding the word "counselor" — if the service functions as therapy, it is covered.
- Strip "AI therapist," "AI counselor," and clinical mental-health positioning from products that do not have genuine licensed-professional oversight.
- This is a marketing-copy audit and a product-behavior audit: a "companion" that drifts into delivering psychotherapy has the same exposure as one that advertises it.
The one-line version#
Disclosure, crisis routing, age state, and a jurisdiction switch are not features you add before launch — they are the session model you launch on. The regime that forced Doubao and Qwen off the market this morning is the same regime a U.S. plaintiff will read your product against. For the full picture of why the two continents diverged, see our wire analysis: China banned the companion; America fenced it.
