Utah enacts AI disclosure law for consumer transactions

Orrick, Herrington & Sutcliffe LLP
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Recently, the Utah Legislature enacted SB 226 (the “Act”), which requires suppliers using generative AI in consumer transactions to disclose such use upon request. Specifically, the new requirements mandate that if an individual asks whether AI is being used, the supplier must inform the individual that the interaction involves generative AI rather than a human. The Act also provides a safe harbor for entities interacting through the use of generative AI if such entities clearly disclose the AI’s involvement at the beginning and throughout the interaction. The Division of Consumer Protection can impose fines of up to $2,500 per violation to reinforce compliance with these new requirements. The law becomes effective on May 7.

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