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ARTICLE · 27 NOVEMBER 2025

AI Chatbots: How To Address Five Key Legal Risks

Wiley Rein
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Companies of all types are deploying chatbots using generative artificial intelligence (GenAI). While these tools offer significant potential benefits, they also present legal and regulatory...

United StatesTechnology
Duane C. Pozza
Duane C. Pozza
Kathleen E. Scott
Kathleen E. Scott
Alissa Lynwood
Alissa Lynwood
Kevin T. Nguyen
Kevin T. Nguyen

Companies of all types are deploying chatbots using generative artificial intelligence (GenAI). While these tools offer significant potential benefits, they also present legal and regulatory risks that must be managed. GenAI chatbots are subject to a complex and growing patchwork of state and federal laws, facing scrutiny from both federal and state regulators. Below we identify five key risk areas that businesses should address as they deploy AI chatbots, as well as best practices to address these risks.

Five Key Risks to Address in Deploying AI Chatbots

1. Chatbots Are Subject to Disclosure and Transparency Requirements.

States have begun to implement AI laws that impose disclosure and transparency requirements on AI chatbots. These laws establish various requirements depending on the chatbots' functions. These include:

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