Rhode Island Splits AI Risk Between Companion Chatbots and Mental-Health Care

Professional legal and mental health compliance workspace with Rhode Island state materials, case files, and laptop review notes.

Rhode Island’s latest AI package is useful because it does not pretend every chatbot problem is the same.

The General Assembly approved one bill aimed at companion-style AI and another aimed at the use of artificial intelligence in therapy and psychotherapy settings. That split matters because the compliance questions are different.

One bill is basically a product-safety and disclosure measure for AI companions. The other is a professional-practice and patient-protection measure for mental-health care. Treating them as one generic "AI safety" story would hide the most practical part.

As of this update, the cleanest official Rhode Island source I found is the General Assembly’s June 8 announcement that both measures were approved and sent to the governor for consideration. So the article below focuses on what the legislature approved and why the two-bill structure is worth watching closely.

The Short Answer

  • Rhode Island’s legislature approved separate AI measures for companion-chatbot safety and for AI use in mental-health care.
  • The companion bill would require crisis protocols, recurring notices that the user is not interacting with a human, annual Attorney General reporting, and expose operators to civil penalties up to $15,000 per day.
  • The mental-health bill would limit how AI can be used in therapy and psychotherapy services, require informed written consent for certain recorded or transcribed sessions, bar unlicensed entities from offering therapy through AI, and keep therapeutic decisions with licensed professionals.

Rhode Island Is Drawing Two Different Regulatory Lines

A lot of AI-law coverage still treats emotionally responsive systems, therapy-like systems, and ordinary chat interfaces as one category.

Rhode Island does not.

Its legislature approved one bill for "artificial intelligence companion models" and another called the "Oversight of Artificial Intelligence Technology in Mental Health Care Act." That is a useful signal because it suggests lawmakers are distinguishing between:

  • consumer-facing systems designed to simulate sustained human-like relationships; and
  • clinical or quasi-clinical use of AI in actual therapy settings.

Those are different products, different risks, and different compliance owners.

The Companion Bill Is About Crisis Protocols and Nonhuman Notice

H 7350 Substitute A as amended would create a new chapter on artificial intelligence companion models.

The definition matters. The bill does not cover every chatbot. It targets systems that simulate a sustained human or human-like relationship by retaining information across sessions, asking unprompted emotion-based questions, and sustaining ongoing personal dialogue. It also excludes ordinary customer-service systems, research or technical-assistance tools, and internal productivity uses.

That narrower definition is exactly what makes the bill practical.

For covered operators, the bill would make it unlawful to operate or provide an AI companion unless the system contains a protocol addressing:

  • possible suicidal ideation or self-harm expressed by a user;
  • possible physical harm to others expressed by a user; and
  • referral to crisis services as soon as those expressions are detected.

The bill would also require a clear and conspicuous notice at the beginning of an interaction and at least every three hours of continued interaction stating verbally or in writing that the user is not communicating with a human.

That recurring-notice structure is worth noticing. Rhode Island is not treating disclosure as a buried one-time term. It is treating nonhuman notice as an ongoing duty for relationship-style systems.

Beginning July 1, 2027, operators would also have to file annual reports with the Attorney General including the number of safety-protocol activations and related metrics, with aggregated data published on the Attorney General’s website.

The enforcement section is not symbolic. It would authorize Attorney General enforcement and civil penalties of up to $15,000 per day, with fines directed to suicide-prevention programs. The bill text says it would take effect on January 1, 2027.

The Mental-Health Bill Is Not A Chatbot-Disclosure Rule

H 7349 Substitute A does something different.

It is not mainly about telling a user they are talking to AI. It is about limiting how AI can be used in therapy and psychotherapy services and preserving the role of licensed professionals.

The bill defines administrative support, supplementary support, therapeutic communication, consent, and permitted uses of AI. It then builds several restrictions on top of those definitions.

Most importantly, it would prohibit licensed professionals or providers from using AI designed to simulate emotional attachment, bonding, or dependency, or AI companions for mental health or emotional support, to assist in supplementary support or therapeutic communication in therapy or psychotherapy services where the client’s therapeutic session is recorded or transcribed unless the patient or authorized representative is informed in writing and provides consent.

That written disclosure must cover:

  • that AI will be used;
  • the specific purpose of the AI tool or system; and
  • written consent to that use.

The bill would also bar any individual, corporation, or entity from providing, advertising, or otherwise offering therapy or psychotherapy services, including through Internet-based AI, unless those services are conducted by a licensed professional or provider.

That is a harder line than a lot of generic "AI in healthcare" commentary suggests.

Therapeutic Decisions Stay With Humans

The part many companies should read most carefully is the section limiting what a licensed professional may let AI do.

Under the bill, a licensed professional or provider could not allow AI to:

  • make independent therapeutic decisions;
  • directly interact with clients in therapeutic communication without an established treatment relationship and appropriate consent; or
  • determine therapeutic recommendations or treatment plans.

The provider retains responsibility for clinical judgment and reasonable therapeutic oversight of the patient’s use of the system, though not for vendor-controlled design, algorithms, or outputs.

That is a strong statement about where Rhode Island thinks professional responsibility should stay. The tool can assist around the edges. It cannot own the treatment decision.

The bill also adds a confidentiality section and gives the Executive Office of Health and Human Services investigative authority. The text says the act would take effect upon passage.

Why The Two-Bill Structure Matters

The practical lesson is that Rhode Island is not regulating "AI" in the abstract.

It is assigning duties based on use case.

If a product is built to simulate emotional attachment or companionship, the pressure point is crisis response, recurring nonhuman disclosure, and reporting. If a product is used in therapy or psychotherapy, the pressure point is consent, licensure, confidentiality, and preserving human clinical judgment.

That split is more useful than a broad AI-principles statute because it maps directly to product, legal, and operational questions companies can actually answer.

What Companies Should Review Now

If these Rhode Island measures matter to the business, the near-term review should be concrete:

  • decide whether any product could fit the legislature’s companion-model definition rather than an ordinary support-tool definition;
  • identify where self-harm and violence escalation protocols live and who owns crisis-referral design;
  • review whether recurring nonhuman disclosures can actually be delivered and logged during long-running sessions;
  • determine whether any mental-health or wellness product is drifting into therapy or psychotherapy claims;
  • review whether recorded or transcribed sessions involving AI would require a separate written-consent workflow; and
  • make sure no vendor or marketing language implies that AI itself is offering therapy where licensure rules would say otherwise.

The bigger point is simple. A lot of AI risk is becoming a classification problem first. What kind of system is this, what kind of use is this, and which rule set attaches once that label is accurate?

Bottom Line

Rhode Island’s legislature approved two AI bills because it appears to see two different problems.

Companion systems raise disclosure, crisis-intervention, and engagement-risk questions. Therapy-related systems raise licensure, consent, confidentiality, and clinical-judgment questions. That separation is the real takeaway.

Even before final governor status is confirmed, the bill texts are a useful picture of where state safeguards are heading. Companies that build emotionally responsive AI or use AI around mental-health services should not treat those as the same compliance lane.

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