Whether you have a duty today depends on where your users are, and the answer changes twice in 2027.
Duty live today · California, New York, Hawaii
California SB 243 since January 2026, New York General Business Law Article 47 since November 2025, Hawaii Act 248 since July 2026. Companies operating there are choosing an evidence-based method now, and will have to defend that choice later.
January 2027 · Washington, Oregon, Colorado, Rhode Island
Colorado’s Attorney General is in rulemaking now. Oregon requires operators to post their annual crisis-referral counts on a publicly accessible website. What you can show in January is decided by what you start measuring this year.
July 2027 · Iowa, Georgia
Iowa SF 2417 (91st General Assembly), enacted as Iowa Code chapter 554J, applies to operators from July 2027, enforced by the Iowa Attorney General with injunctive relief and the greater of actual damages or $1,000 per violation up to $500,000. Georgia SB 540 takes effect that month too, as does California’s annual reporting to the Office of Suicide Prevention.
Everywhere else · no duty yet
The same systems, the same behavior, no legal obligation on the calendar. Yet. Buyers here are usually answering a carrier, a board, an acquirer or a customer rather than a regulator.
Every one of them requires a protocol. None of them defines how to measure whether you followed it.
California’s companion-AI law tells operators to use “evidence-based methods for measuring suicidal ideation.” It never defines what counts as evidence-based. Every operator in scope is choosing a method right now, by default, and will have to defend that choice later.
California is the state that names a measurement surface: its statute specifies what gets counted and reported, and requires it to be published. Iowa’s chapter 554J does the opposite. It sets duties and is silent on how compliance is measured or demonstrated, with no reporting, recordkeeping or audit requirement, leaving enforcement to the Attorney General against undefined standards of reasonable safeguards and reasonable efforts.
In Europe, the AI Act’s Article 50 duty to tell people they are talking to a machine applies from August 2026, with no grace period. The Digital Omnibus on AI, in force since July 2026, moved the Annex III high-risk obligations to December 2027 and the embedded-product obligations to August 2028.
The checkers are being appointed.
The enforcement side is being staffed right now. Colorado’s Attorney General is in rulemaking. California requires annual reporting to the Office of Suicide Prevention from July 2027. Oregon requires operators to post referral counts publicly from January 2027. Iowa’s Attorney General enforces chapter 554J from July 2027.
Whether any method satisfies a particular requirement is a determination for your counsel. Ikwe does not advise on which laws apply to you. What Ikwe does is produce the record you would want to have when the question is asked.