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ARTICLE · 07 MARCH 2025

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Virginia Poised To Become Second State To Enact Comprehensive AI Legislation

Greenberg Traurig
Greenberg Traurig
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Greenberg Traurig

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On Feb. 20, 2024, the Virginia General Assembly passed the High-Risk Artificial Intelligence (AI) Developer and Deployer Act (HB 2094).

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Go-To Guide:
  • Virginia's HB 2094 applies to high-risk AI system developers and deployers and focuses on consumer protection.
  • The bill covers AI systems that autonomously make or significantly influence consequential decisions without meaningful human oversight.
  • Developers must document system limits, ensure transparency, and manage risks, while deployers must disclose AI usage and conduct impact assessments.
  • Generative AI outputs must be identifiable, with limited exceptions.
  • The attorney general would oversee enforcement, with penalties up to $10,000 per violation and a discretionary 45-day cure period.
  • HB 2094 is narrower than the Colorado AI Act (CAIA, with clearer transparency obligations and trade secret protections, and differs from the EU AI Act, which imposes stricter, risk-based compliance rules.

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