Legislating AI Chatbots for Minors in Oklahoma
I’ve been watching a flurry of legislative activity in 2026 around restrictions on chatbots for minors across the United States, including in Oklahoma. While the topic seems simple enough on the surface, let’s dig into the political, legal, and technical considerations.
BACKGROUND
In April 2025, a Rancho Santa Margarita, California based teen named Adam Raine tragically committed suicide at the age of 17 and his parents later discovered he had used ChatGPT extensively in the lead-up, bypassing guardrails in place. This is a truly heartbreaking story.
Adam’s parents filed a lawsuit against OpenAI in the Superior Court of California saying ChatGPT contributed to their son’s suicide by encouraging his suicidal ideation. This was the first wrongful death lawsuit filed against OpenAI.
While ChatGPT prompted the teen to access crisis resources and trusted individuals over 100 times, he was still able to ultimately bypass the anti-suicide guardrails. The product went so far as to assist in writing a suicide note and acting as a suicide coach.
In response, Sam Altman, the CEO of OpenAI said, “we prioritize safety ahead of privacy and freedom for teens; this is a new and powerful technology, and we believe minors need significant protection.”
OpenAI immediately took action and rolled out additional new safeguards to include 1) strengthened crisis resources inside the product, 2) parental monitoring for parents which includes alerts if acute stress is detected, and 3) an age-estimation capability that is being developed which will default to a stricter product if it predicts you are under 18.
POLITICAL
In my previous post featuring Representative Daniel Pae, we talked about President Trump’s December 2025 Executive Order on AI. This directive has a goal of federalizing AI regulation with a “one rule” policy so that an American business would, in theory, comply with a single, overarching rule on AI in the US - not 50+ different rules (and associated compliance costs) across different states and cities.
Interestingly, the Executive Order provided a carveout for child safety signaling a green light for states to move on this topic. The order states it “shall not propose preempting otherwise lawful State AI laws relating to: (i) child safety protections.”
Last month, the Transparency Coalition noted there are 78 legislative proposals across 27 states on chatbots - with a majority being focused on minors.
In Oklahoma, two bills on the topic, Senate Bill 1521 and House Bill 3544, are being considered this legislative session. The bills, in the current versions as of March 19, 2026, 1) restrict or prohibit AI chatbots with human-like features from being made available to minors (HB3544), 2) mandate age certification or verification systems (HB2544), and 3) address the risks of self-harm and suicidal ideation (SB1521, HB3544).
While similar in spirit, there are some differences in the two bills, to include civil penalties ranging from $100-$750 per intentional violation in the current House Bill to $1,000-$500,000 per infraction in the Senate Bill.
From here, both legislative chambers would have to agree on a single set of language and then the Governor would have to sign the bill for it to become law.
LEGAL
Oklahomans should be aware of legislative efforts that could potentially face costly court challenges. Bills like this could be challenged for data privacy concerns, potential free speech violations, chilling speech grounds, or other concerns. The First Amendment protects not only the right to speak, but the right to create, disseminate, and access speech.
According to Anthony Hendricks, Shareholder and Director at Oklahoma’s Crowe & Dunlevy law firm:
“From a legal standpoint, other states have run into constitutional issues on bills like this around free speech, and chilling speech issues.
Both children and parents have First Amendment rights. Which means that not only do children have a right to free speech, but parents also have the right to make decisions about how their children access speech online. As a result, legislation like this has to be narrowly tailored and must address a compelling government interest to be successful.
We’ve seen courts in Arkansas, Louisiana, Ohio, Texas, and Georgia strike down state-level social media age-verification laws. The courts have consistently held that age verification laws should not impose a substantial burden on people’s ability to access these sites, and the law must be narrow so as not to destroy anonymous speech online.
While the AI age-restriction bills are focused on protecting children, they would require Oklahomans of all ages to provide companies with personal information to verify their age. Age verification typically requires people to provide their name, ID card, or even credit card information to prove they are an adult. If you have to provide your ID or credit card before using an AI chatbot, will you still use the AI chatbot in the same way you would have, if you were anonymous?
These privacy and First Amendment concerns also have to be balanced with protecting our children. There have been countless stories of children using AI to harm themselves. Earlier this year, both Character.AI and Google settled multiple lawsuits that AI chatbots contributed to mental health issues that led to the suicide of teens. So our legislators are right to be looking at ways to protect our children.”
TECHNICAL
Let’s unpack the technical implications on the prohibition of chatbots for minors in HB3544.
“Each deployer: Shall ensure that any artificial intelligence (AI) chatbot operated or distributed by the deployer that has human-like features is not made available to minors to use, interact with, purchase, or converse with.”
There is a saying I come back to often: we must face reality as it is, not as we wish it to be. Today, Generative AI models are actively being integrated across nearly all software systems that we use personally and professionally. Companies across every industry and domain are spending significant investment dollars to update existing systems, tools, and processes to make full use of AI for employees and customers. The primary interface will be voice or text chat, with increasingly human-like capabilities that offer deep personalization.
The definitions of “chatbot” & “human-like” are a compliance trap. Chatbot and human-like are defined broadly, and it could sweep huge categories of software under the bill’s regulation. Modern assistants aren’t used only for one category - they’re general-purpose systems with personalization and memory.
As Apple integrates Google Gemini into Siri later this year, it will be embedded in everything an Apple device does. The ubiquity of this technology inspires the question - could this legislation cause millions of infractions daily and potentially prevent Apple from selling iPhones in Oklahoma?
Generative AI cannot be effectively compared to traditional software. It doesn’t perform a repeatable task. Every time you use it, the output is different. AI models continue to get smarter, each day. The same design flexibility that makes these models creative is also what makes guardrails technically difficult to enforce. Nevertheless, requiring safeguards and protecting children and teens is a societal must.
I see a real risk for a ban like this to be lose-lose. Either HB3544 is strictly enforced, and it pulls in mainstream tools like search engines, or it is enforced loosely and bad actors simply label themselves “productivity,” and we fail to protect children.
While well intentioned, a complete ban would risk requiring broad data collection for nearly all software, hamper job opportunities and economic development, encourage an exodus of employers from the state, kill investment in Oklahoma’s companies and industries, serve as a magnet for litigation and class-action cases, and even push companies to geofence Oklahoma.
One technical expert shared with me, “by forcing industry to consider every use case and intentional or accidental access by minors, these bills will dramatically increase the cost of doing business in Oklahoma. In many cases, this will make doing business in Oklahoma completely impossible.”
RECOMMENDATION
Reflecting back on Adam Raine, my first recommendation would be that the federal government create a national federal policy on child safety and AI. As we discussed, today there is a carveout on child safety in the President’s Executive Order on AI which could lead to 50 different policies across each state to the detriment of children and businesses alike. For Oklahoma businesses who operate in multiple states, this could be complicated at best and catastrophic at worst. For children, it could result in lack of protection and missed opportunities.
A single, federal policy would ensure children are protected and that no state is penalized from operating with AI-enabled services and products. Specifically, I’d like to see strong, active guardrails to protect children in the policy, including required measures and protocols for self-harm conversations. With OpenAI and other leading AI companies already taking these steps proactively in the market, we need to make sure the industry follows at large.
In the absence of federal policy and in light existing case law striking down age verification in light of the First Amendment, my second recommendation would be that we look at refining our state bills to focus on language around strengthening guardrails.
Finally, I disagree with having a blanket ban on chatbots for minors. As an educator we must ensure our students are ready to work, compete, and lead in our AI economy which means access, in age appropriate and safe ways, to AI tools.
Unfortunately, the reality is Oklahoma is ranked last - 50th - in the country in education. AI presents us with perhaps the most profound tool ever created to provide individualized education for our children. In Texas there is a school called the Alpha School that is leaning into AI-first education. Alpha is seeing their kids score in the top 1-2% nationally and at elite global levels on tests. While Alpha is a private school with a specific model, the principle of AI-personalized instruction support tailored to every student is an enormous gift. It is also a national security necessity to make sure our children are not ignorant of the tools and capabilities of a new industrial era.
When cars were introduced, seat belts were not an immediate requirement. The laws came after some time we as a culture recognized the benefits of safety outweighed the risks and we were willing to exchange some of our personal freedoms. As we move forward, we owe it to kids like Adam Raine to have strengthened guardrails in AI systems. We need seat belts though, not a ban on driving.