# AB 1609: Customer Service Chatbots (Right to Human Customer Service Act)

Source: https://www.bankingnewsai.com/ai-regulation/documents/ca-ab-1609-2026
Last updated: Oct 5, 2026

AB 1609, signed by Governor Newsom on September 28, 2026 (Chapter 733, Statutes of 2026) and operative January 1, 2027, adds Chapter 22.6.1 (Sections 22625–22629) to the Business and Professions Code. It bars a large private business (over $500 million in national gross annual revenue) from representing that a customer service chatbot is human, requires a clear and conspicuous AI disclosure whenever a reasonable person could otherwise be misled, and requires a way to request a human agent — with a good-faith effort to connect within 15 minutes or schedule an appointment within one business day. A public prosecutor enforces it; there is no private right of action; penalties run $5,000 for an initial violation and $10,000 for each subsequent one.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [California CPPA](https://www.bankingnewsai.com/ai-regulation/california) |
| Type | Statute |
| Status | Final · applies from Jan 1, 2027 |
| Published | Sep 28, 2026 |
| Effective | Jan 1, 2027 |
| Applies to | Any "large private business" — more than $500 million in gross annual revenue nationally — that provides goods or services to California customers through a customer service chatbot or telephonic customer service, including bank and credit-union retail and support lines |
| Official text | https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1609 |

## Key points

- Applies only to "large private businesses" — more than $500,000,000 in gross annual revenue nationally — so it reaches large banks and card issuers but not community banks or credit unions
- Prohibits representing a customer service chatbot as a human, and requires a clear, conspicuous AI disclosure in the same medium as the interaction whenever a reasonable person could be misled
- Requires a simple way for a customer to request a human agent on every customer-service channel (chat or telephonic) during regular business hours
- Good-faith effort to connect to a human agent within 15 minutes of the request, or schedule an appointment within one business day; hold/wait time after connection capped at 15 minutes per instance and one hour cumulative
- Enforced only by a public prosecutor — the statute expressly creates no private right of action — with penalties of $5,000 for an initial violation and $10,000 for each subsequent violation
- Exempts exclusive business-to-business lines, hospitals' health-care communications, consumer reporting agencies, and businesses that comply with specified Public Utilities Commission rules; excuses noncompliance caused by unforeseen circumstances or emergencies
- A business need not offer telephonic customer service if it did not already do so as of January 1, 2027, provided customers can still promptly reach a human through another channel

## What changed for banks

California becomes the first state to regulate bank-facing customer-service chatbots directly, rather than through its general privacy or employment statutes. For large banks it adds a disclosure-and-human-escalation duty layered on top of (not a substitute for) the CPPA's ADMT rules and the Colorado Chatbot Safety Act obligations that already reach customer-facing AI.

## Use cases it governs

- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)

## FAQ

### Does AB 1609 apply to all banks operating in California?

No. It only applies to a "large private business" with more than $500 million in gross annual revenue nationally. Community banks and most credit unions fall below that threshold.

### When does AB 1609 take effect?

January 1, 2027. It was signed September 28, 2026 as Chapter 733, Statutes of 2026.

### Can a customer sue a bank directly under AB 1609?

No. The statute creates no private right of action; it may be enforced only by a public prosecutor, with civil penalties of $5,000 for an initial violation and $10,000 for each subsequent violation.

## Related documents

- [SB 947](https://www.bankingnewsai.com/ai-regulation/documents/ca-sb-947-2026) — Employment: Automated Decision Systems (No Robo Bosses Act) (Sep 30, 2026)
- [CPPA ADMT, risk-assessment and cybersecurity-audit regulations](https://www.bankingnewsai.com/ai-regulation/documents/ca-cppa-admt-risk-cyber-regulations-2025) — CCPA Updates, Cybersecurity Audits, Risk Assessments, Automated Decisionmaking Technology, and Insurance Companies — approved regulation text (11 CCR Division 6) (Sep 22, 2025)
- [Civil Rights Council ADS employment regulations](https://www.bankingnewsai.com/ai-regulation/documents/ca-crc-ads-employment-regulations-2025) — Modifications to Employment Regulations Regarding Automated-Decision Systems (Fair Employment and Housing Act regulations, 2 CCR) (Jun 27, 2025)
- [California AG legal advisory on AI (Jan 2025)](https://www.bankingnewsai.com/ai-regulation/documents/ca-ag-legal-advisory-ai-2025) — Legal Advisory: Application of Existing California Laws to Artificial Intelligence (Jan 13, 2025)
- [Cal. Civ. Code §1798.145 (CCPA exemptions, incl. GLBA data)](https://www.bankingnewsai.com/ai-regulation/documents/ca-civil-code-1798-145) — California Consumer Privacy Act — exemptions, including the data-level exemption for information subject to the Gramm-Leach-Bliley Act and the California Financial Information Privacy Act (Civil Code §1798.145) (Jun 28, 2018)
- [Colorado AG proposed ADMT rules](https://www.bankingnewsai.com/ai-regulation/documents/co-ag-admt-proposed-rules-2026) — Proposed Automated Decision-Making Technology and Conversational AI Service Rules (Notice of Rulemaking Hearing) (Aug 11, 2026)
- [Regulation (EU) 2026/1744 (Digital Omnibus on AI)](https://www.bankingnewsai.com/ai-regulation/documents/eu-digital-omnibus-ai-regulation-2026-1744) — Regulation (EU) 2026/1744 amending Regulation (EU) 2024/1689 as regards the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI) (Jul 24, 2026)
- [HB 26-1263](https://www.bankingnewsai.com/ai-regulation/documents/co-hb26-1263) — Conversational Artificial Intelligence Service Operator Requirements (Chatbot Safety Act) (May 29, 2026)

Last reviewed Oct 5, 2026. Cite the official text (https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1609) for the rule and this page for the summary and dates.

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