On December 10, 2025, a bipartisan coalition of U.S. state attorneys general warned that major AI chatbots may be violating state laws and set a response deadline of January 16, 2026. The letter calls out risks like harmful or misleading advice (including to minors), dark patterns, and a lack of accountability — and signals that developers may be held responsible for their agents’ outputs. See reporting at The Verge and Reuters for the essentials.

• The Verge coverage
• Reuters summary

For founders, operators, and e‑commerce teams shipping chatbots or autonomous agents, this is not a PR blip — it’s a roadmap requirement. It lands just as OpenAI’s GPT‑5.2 and Google’s next‑gen agents raise product ambitions, making safety and governance the difference between growth and legal risk.

What the AGs want (decoded for builders)

• Safer outputs for the public and minors: Reduce harmful, manipulative, or sycophantic behavior; implement age‑aware experiences.
• Clear warnings and disclosures: When the bot is non‑professional or fallible, say so — in the right places and moments.
• No dark patterns: Don’t design prompts, defaults, or flows that push risky actions or hide key choices.
• Independent audits and accountability: Be ready to show evaluators your controls, logs, and incident processes.

If you missed it, read our policy primer: The New U.S. AI Executive Order: What Startups Must Ship in the Next 7 Days.

Your 7‑Day Compliance Sprint

Use this action plan to harden your chatbot/agent this week. It’s written for lean teams — prioritize the highest‑risk surfaces first.

Day 1 — Risk Triage and Guardrail Freeze

• Inventory every user‑facing capability (refunds, medical/legal advice, self‑harm, age‑sensitive topics, device control, browsing/tools).
• Temporarily disable or route to human any flow that can cause safety, financial, or physical harm.
• Implement basic blocks: illegal instructions, explicit self‑harm, medical and legal advice without disclaimers and handoff.

Day 2 — Age Gating and Minor Protections

• Add a lightweight age affirmation at session start; for accounts, store age status server‑side.
• Shift minors to a restricted response set (supportive, non‑diagnostic, information‑only) with clear escalation to guardians or hotlines when appropriate.
• Mask and minimize PII; auto‑redact sensitive fields in logs.

Day 3 — Disclosures, Choices, and Data Use

• Place inline, contextual disclosures next to risky affordances: “This is not medical/legal advice.” “May be inaccurate.” Link to Safety Policy.
• Expose clear choices: opt‑in/out of data use for model improvement; easy “Report a harmful answer” control.
• Brand‑safe output: for licensed IP or brand voice, enforce templates and content filters. (See our take on brand licensing risk in this 7‑day playbook.)

Day 4 — Run Real Safety Evals (and publish the results)

• Test harmful‑content refusal, age‑aware behaviors, and manipulation resistance.
• Benchmark end‑to‑end tasks using the same agent evals we recommend for reasoning/browsing: DeepSearchQA, BrowserComp, and HLE.
• Log violations, human handoffs, tool denials, and time‑to‑contain — then fix the top 10% of issues.

Day 5 — Ship an Agent Firewall

• Whitelist tools and data sources; deny by default anything not explicitly allowed.
• Secrets live in a vault; require policy checks before tool calls (refunds, emails, code execution, purchases).
• Start with our guide: Agent Firewalls Are Here.

Day 6 — Audit Trail, Incident Response, and Third‑Party Readiness

• Create tamper‑evident logs for prompts, tool calls, guardrail decisions, overrides, and human interventions.
• Write a one‑page Safety Incident SOP: detection → containment → user notice → fix → post‑mortem within 72 hours.
• Prepare a “Regulator Binder”: model cards used, eval scores, safety policies, data retention, vendor list, and contact.

Day 7 — Update Policies, UX, and Messaging

• Refresh Terms, Privacy, and Safety Policy to reflect age gating, audits, data use choices, and incident process.
• Add a Safety Center page in your app with: disclosures, reporting form, eval summaries, and change log.
• Publish a brief Release Note so customers, partners, and (yes) AGs can see you acted before the Jan 16 deadline.

Founder FAQs

“We use frontier models — do we still need all this?”

Yes. Even if model‑level safeguards improve (see OpenAI’s GPT‑5.2 focus on fewer hallucinations), your product can still induce risk via prompts, tools, UX, and data flows. Treat product layer governance as non‑negotiable.

“What counts as a dark pattern in AI?”

Examples: nudging users to keep chatting after risky advice, hiding the human‑handoff, or pre‑ticking “use my data to improve models.” Default to explicit, revocable consent and clear exits to humans.

“We sell to e‑commerce. What’s the minimum viable compliance?”

• Human approval for refunds, cancellations, or price overrides above set thresholds.
• Age‑aware flows for product categories with restrictions (alcohol, supplements).
• Clear “not medical advice” language for wellness queries and quick escalation to a human advisor.

Metrics to track (and show auditors)

• Violation rate (unsafe output per 1,000 chats) and time‑to‑contain.
• Handoff coverage: % of high‑risk intents that route to a human within N seconds.
• Age‑aware correctness: refusal + safe alternate response rate for minor‑flagged sessions.
• Tool call allow/deny ratio under policy checks (look for regressions after releases).

Ship it faster with HireNinja

If you don’t have bandwidth to build all this from scratch, HireNinja can help you stand up guardrails, evals, and audit trails quickly.

• Prebuilt agent policies for refunds, emails, browsing, and data access.
• Agent Firewall patterns (deny‑by‑default tools, allowlists, secret vault hooks).
• One‑click eval suites for safety behaviors and end‑to‑end tasks.
• Audit‑ready logs with redaction and export.

Get started with HireNinja or reply to this post and we’ll help tailor a 7‑day sprint for your product.

Keep Reading

• The New U.S. AI Executive Order: What Startups Must Ship in the Next 7 Days
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• Agent Firewalls Are Here
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