California's Customer Service Chatbot Law (AB 1609), Explained
By Alex (J.D. candidate, not a lawyer)
California's customer service chatbot law is AB 1609 (Stats. 2026, ch. 733). It adds Business and Professions Code sections 22625 to 22629, which set rules for customer service chatbots used by large private businesses. The Governor signed it on September 28, 2026. Beginning January 1, 2027, the law bars a covered business from presenting its chatbot as human and sets rules for reaching a person. This page walks through the signed text, section by section.
What AB 1609 is
AB 1609 is Chapter 733 of the Statutes of 2026. It adds a new chapter, "Customer Service Chatbots", to the Business and Professions Code, made up of sections 22625 through 22629. Leginfo shows it was approved by the Governor and filed with the Secretary of State on September 28, 2026. (Read the bill on leginfo.)
The bill's author, Assemblymember Rick Chavez Zbur, calls it the "Right to Human Customer Service Act." The signed text gives the law no short title. (Read the author's press release.)
For the bill's status alongside other California AI laws, see the tracker entry for AB 1609.
Which businesses it covers
What the law says. Section 22625(g) defines the businesses the law reaches: "'Large private business' means a business with more than five hundred million dollars ($500,000,000) in gross annual revenue nationally that provides goods and services to customers."
Section 22625(d) defines the technology: "'Customer service chatbot' means an artificial intelligence system with a natural language interface that provides adaptive, human-like responses to user inputs and is used by an entity for any of the following purposes: (1) Direct customer service, including service to prospective and existing customers, relating to the sale or delivery of goods or services. (2) Direct customer support, including technical assistance functions relating to the sale or delivery of goods or services."
Section 22625(j) defines "services": "'Services' means services for which a customer will provide or has provided monetary consideration, whether through a one-time payment, subscription, fee, or recurring charge. 'Services' does not include services or parts of services that offer a free option to persons with an opportunity to pay, subscribe, or otherwise provide monetary consideration for the service or upgraded services at a future time."
Section 22628(g) lists what the chapter does not apply to: certain services regulated by the Public Utilities Commission, exclusive business lines, certain hospital communications about health care, and consumer reporting agencies. (Read the official text.)
What it means in general. Coverage turns on the defined terms in section 22625, read together with the section 22628(g) list.
The chatbot cannot claim to be human
What the law says. Section 22626(a) says: "A large private business shall not represent that a customer service chatbot is a human."
Section 22626(b) says: "A large private business shall provide a clear and conspicuous disclosure that the customer service chatbot is artificially generated and not human if a reasonable person interacting with the customer service chatbot is likely to be misled to believe that the person is interacting with a human."
Section 22626(c) adds that the disclosure "shall be clear and conspicuous, and provided in the medium in which the customer service chatbot interacts with the customer." (Read the official text.)
What it means in general. Section 22626 sets two rules. One is a flat bar on representing a chatbot as a human. The other is a disclosure duty that applies when a reasonable person is likely to be misled.
Asking for a person
What the law says. Section 22627 sets four duties for a large private business:
- A request feature. "During at least a large private business's regular business hours," the business must provide a simple customer service feature that "allows customers to request to connect to a customer service agent." (22627(a))
- Connection or an appointment. The business "shall make a good faith effort" to give a customer who asks either "[c]onnection to a customer service agent within 15 minutes of the request" or "[a] specific appointment time within one business day of the request". (22627(b)(1)) A business subject to section 1707.2 of Title 16 of the California Code of Regulations "may satisfy the requirements in paragraph (1) by returning a phone call within one business hour." (22627(b)(2))
- Hold times. The business "shall make a good faith effort to ensure a customer is not placed on hold or made to wait for more than 15 minutes at any time after connection with a customer service agent, and that cumulative hold or wait times or escalation queues do not exceed more than one hour total." (22627(c))
- Posting a phone number. This applies only to businesses that serve California customers "through online platforms and who have a telephonic customer service platform". They "shall post their telephonic customer service telephone number clearly and conspicuously on their internet website." (22627(d))
What it means in general. Section 22625(i) defines "regular business hours", and section 22625(c) defines "customer service agent" as a natural person. Duties 2 and 3 use a "good faith effort" standard.
What the section does not require
Section 22627(e) says the section does not require a large private business to do any of the following:
(1) To connect or respond within 15 minutes if the request or connection is made via electronic mail, web-based contact form, or voicemail message.
(2) To offer customer service through a communication platform that the business has not otherwise made available to customers as of January 1, 2027.
Who enforces it
What the law says. Section 22628(a) says: "An action to enforce this chapter may be brought by a public prosecutor." Under section 22628(b), a large private business that violates the chapter "shall be liable for a civil penalty not exceeding five thousand dollars ($5,000) for an initial violation, and ten thousand dollars ($10,000) for each subsequent violation." Section 22628(c) says that "the use of commercially reasonable and practicable standards that are designed and intended to achieve compliance shall satisfy the 'good faith effort' requirements of Section 22627." Under section 22628(f), a business's inability to comply is not a violation if it is due to "[u]nforeseen circumstances beyond its reasonable control" or "[e]xtraordinary or emergency situations". Section 22628(g) lists what the chapter does not apply to. Section 22628(d) says: "This chapter does not establish a private right of action." (Read the official text.)
When it starts
AB 1609 takes effect January 1, 2027. It was signed September 28, 2026, and under the California Constitution a statute passed at a regular session takes effect on January 1 after a 90-day period from its enactment (Cal. Const., art. IV, § 8(c)(1)). (Read the official text.)
How it fits with other California bot laws
California already had a general bot law. Section 17941 says:
(a) It shall be unlawful for any person to use a bot to communicate or interact with another person in California online, with the intent to mislead the other person about its artificial identity for the purpose of knowingly deceiving the person about the content of the communication in order to incentivize a purchase or sale of goods or services in a commercial transaction or to influence a vote in an election. A person using a bot shall not be liable under this section if the person discloses that it is a bot.
(b) The disclosure required by this section shall be clear, conspicuous, and reasonably designed to inform persons with whom the bot communicates or interacts that it is a bot.
A separate law, SB 243 (Stats. 2025, ch. 677), covers companion chatbots. Its section 22602(a) says: "If a reasonable person interacting with a companion chatbot would be misled to believe that the person is interacting with a human, an operator shall issue a clear and conspicuous notification indicating that the companion chatbot is artificially generated and not human." (Read the official text.)
Section 22601(b)(1) defines the term: "'Companion chatbot' means an artificial intelligence system with a natural language interface that provides adaptive, human-like responses to user inputs and is capable of meeting a user's social needs, including by exhibiting anthropomorphic features and being able to sustain a relationship across multiple interactions." Section 22601(b)(2)(A) says the term does not include "[a] bot that is used only for customer service, a business' operational purposes, productivity and analysis related to source information, internal research, or technical assistance." Section 22601 lists two more exclusions, in subparagraphs (B) and (C). Read the official text.
AB 1609 ends with section 22629: "The duties, remedies, and obligations imposed by this chapter are cumulative to the duties, remedies, or obligations imposed under other law and shall not be construed to relieve a large private business from any duties, remedies, or obligations imposed under any other law."
Sources
- AB 1609 (2025-2026), Stats. 2026, ch. 733, adding Business and Professions Code sections 22625 to 22629. Read the bill on leginfo. Bill history.
- California Constitution, article IV, section 8, subdivision (c)(1).
- Business and Professions Code section 17941 (added Stats. 2018, ch. 892).
- Business and Professions Code section 22601 and section 22602 (added Stats. 2025, ch. 677); section 22602 amended by Stats. 2026, ch. 190 (SB 1119), effective January 1, 2027.
SentryHall publishes general legal information for educational purposes. It is not legal advice, and reading it does not create an attorney-client relationship. The author is a law student, not a lawyer. Laws change and apply differently to different facts. For advice about your situation, talk with a lawyer licensed in California. You can look up a lawyer's license status at calbar.ca.gov.