On April 30, 2026, the U.S. Senate Judiciary Committee unanimously advanced S. 3062, the Guidelines for User Age-verification and Responsible Dialogue Act of 2025 (the “GUARD Act”), marking a significant development in federal efforts to regulate certain uses of artificial intelligence (AI) involving minors. The bill now awaits consideration by the full Senate.

Senators Hawley (R-MO) and Blumenthal (D-CT) introduced the legislation in October 2025, and a bipartisan group of seventeen senators are cosponsors. The legislation focuses on regulating AI chatbots that are publicly available to consumers, with particular attention to the risks associated with use by minors under the age of eighteen.

The bill prohibits making AI chatbots publicly available while knowing or recklessly disregarding the fact that the AI chatbot:

  • Encourages suicide, self-injury, homicide, or imminent physical or sexual violence;  
  • Engages minors in certain sexual conversations; or
  • Makes available to minors depictions of sexual conduct.

The legislation also obligates AI chatbots to disclose clearly that users are interacting with a non‑human system and that the system does not hold professional credentials—like those of a licensed therapist, medical professional, or attorney—or provides medical, legal, financial, or psychological services.

Critically, the bill further requires user accounts to use AI companions, defined as AI chatbots that simulate a sustained interpersonal relationship or emotional interaction through certain types of responses. Entities that make AI companions publicly available to end consumers are mandated to implement “reasonable age verification measures” for all user accounts. Where a user is determined to be a minor under the age of eighteen, the provider would be prohibited from allowing access to AI companions.

To enforce its provisions, the GUARD Act would empower both the U.S. Attorney General and State Attorneys General to bring civil actions enjoining violations of the legislation, and the U.S. Attorney General would be able to pursue civil penalties of up to $250,000 per violation as well. There is also criminal liability for companies that violate the bill’s prohibitions on encouraging suicide, self-harm, or physical violence or exposing minors to sexual content, with fines of up to $250,000 per offense.

Following its unanimous committee approval, the GUARD Act moves on to the full Senate. While companion legislation has already been introduced in the House, there is still significant opposition from some electronic privacy and First Amendment-focused organizations, and the bill may undergo further changes. Nonetheless, at least the Senate has previously passed online safety legislation this Congress, so further movement remains a possibility.

Photo of Nicholas Xenakis Nicholas Xenakis

Nick Xenakis draws on his Capitol Hill and legal experience to provide public policy and crisis management counsel to clients in a range of industries.

Nick assists clients in developing and implementing policy solutions to litigation and regulatory matters, including on issues involving…

Nick Xenakis draws on his Capitol Hill and legal experience to provide public policy and crisis management counsel to clients in a range of industries.

Nick assists clients in developing and implementing policy solutions to litigation and regulatory matters, including on issues involving antitrust, artificial intelligence, bankruptcy, criminal justice, financial services, immigration, intellectual property, life sciences, national security, and technology. He also represents companies and individuals in investigations before U.S. Senate and House Committees.

Nick previously served as General Counsel for the U.S. Senate Judiciary Committee, where he managed committee staff and directed legislative efforts. He also participated in key judicial and Cabinet confirmations, including of Attorneys General and Supreme Court Justices. Before his time on Capitol Hill, Nick served as an attorney with the Federal Public Defender’s Office for the Eastern District of Virginia.

Photo of Diana Lee Diana Lee

Diana Lee is an associate in the technology regulatory group. She counsels clients on a range of regulatory and litigation matters involving electronic surveillance, government demands for data, national security, and data privacy and cybersecurity issues, with a particular focus on cross-border and…

Diana Lee is an associate in the technology regulatory group. She counsels clients on a range of regulatory and litigation matters involving electronic surveillance, government demands for data, national security, and data privacy and cybersecurity issues, with a particular focus on cross-border and multi-jurisdictional concerns.

Before rejoining the firm, Diana clerked for the Honorable Victor A. Bolden on the U.S. District Court for the District of Connecticut.

Diana is a member of the Bars of New York and the District of Columbia.

Photo of Evan Chiacchiaro Evan Chiacchiaro

Evan Chiacchiaro is an associate in the firm’s Washington, DC office and member of the Technology and Communications Regulation Practice Group.

Evan advises clients on a range of technology regulatory issues, including emerging artificial intelligence compliance matters and compliance with Federal Communications Commission…

Evan Chiacchiaro is an associate in the firm’s Washington, DC office and member of the Technology and Communications Regulation Practice Group.

Evan advises clients on a range of technology regulatory issues, including emerging artificial intelligence compliance matters and compliance with Federal Communications Commission (FCC) regulations. Evan also maintains an active pro bono practice focused on civil rights.