California B.O.T. Act: What You Need to Know About Bot Disclosure in 2026

Who This Law Covers

The California B.O.T. Act applies to any individual or company that operates a bot or automated account to communicate online with people in California. The law specifically targets bots used for two purposes: (1) to mislead people into buying goods or services, or (2) to mislead people about voting in elections.

The law covers anyone who owns or operates the bot, regardless of whether they built it themselves or hired someone else to build it. If you are using a bot to interact with California residents, you are responsible for complying with the disclosure requirement.

The law does NOT apply to internet service providers or web hosting companies just because they host bot software. The responsibility falls on the person or business actually running the bot. Banks, financial institutions, and other entities offering legitimate customer service through bots are not the target of this law if their purpose is not deception.

If you operate a bot that does not interact with people in California, or if your bot is not used for commercial sales or election influence, this law does not apply to you.

What It Actually Requires

The core requirement under the statute is that disclosure must be clear and conspicuous. The law requires the disclosure to be reasonably designed to inform the person that they are communicating with an automated account, not a human.

The statute uses the terms 'clear' and 'conspicuous' but does not specify where or when the disclosure must appear. The most protective approach to compliance is to place disclosure early in the interaction, where a person is likely to notice it before deciding whether to engage with the bot.

The statute contains an explicit safe harbor: a person using a bot is not liable under this section if the person discloses that it is a bot. The disclosure must be clear, conspicuous, and reasonably designed to inform the people the bot communicates or interacts with that it is a bot.

The law does not require you to use specific wording or a particular phrase. It only requires that the disclosure be clear and conspicuous enough that a reasonable person would understand they are talking to a bot.

Deadlines and Penalties

The law took effect on July 1, 2019, and has been in force ever since. There is no grace period or future deadline to prepare. The law applies immediately to bots currently communicating with people in California.

Violations are enforced under California's unfair competition law. The statute itself does not specify a fixed dollar amount per violation. Instead, enforcement is handled through the state's broader consumer protection framework, which means penalties can vary depending on the nature and severity of the violation.

Because the law lacks a specific dollar penalty in its text, enforcement typically falls to California's Attorney General or consumers themselves through civil lawsuits. Businesses that violate the disclosure requirement may face legal action, but the exact financial consequence depends on how a court or regulatory authority evaluates the specific violation.

How Courts and Experts Interpret the Law

The law requires disclosure to be 'clear and conspicuous.' Legal experts and compliance guidance generally recommend placing disclosure prominently in the initial interaction with the bot, though the statute's language does not explicitly mandate placement within the conversation itself versus other locations.

Examples of approaches that attempt to meet the clear and conspicuous standard include: starting the bot's first response with 'This is an automated bot,' using a pop-up or banner stating the same before the user can interact, or displaying a clear label on the button or link that triggers the bot.

Some guidance suggests that burying disclosure in terms of service, footer links, or profile descriptions alone is less likely to satisfy the 'clear and conspicuous' requirement, since a person may not see it before or during interaction. However, the statute itself does not prohibit these locations if they are genuinely clear and conspicuous.

If you use a bot to sell products or influence votes, the disclosure requirement applies the same way. The law does not exempt any particular purpose or business type, as long as the bot operates for the stated purposes and the disclosure is adequate.

Common Misconceptions

Misconception: 'I can hide that my account is a bot as long as I disclose it somewhere on my website.' Fact: The law requires disclosure to be clear and conspicuous. Most legal guidance indicates this means a person must encounter the disclosure before or during interaction with the bot, not in a hidden or hard-to-find location.

Misconception: 'The penalty is $1,000 per violation' or 'There is a set fine.' Fact: The law itself does not specify a fixed dollar amount. Penalties vary based on enforcement actions and how courts evaluate the violation. Do not rely on a specific number found in secondary sources.

Misconception: 'My bot is fine because it is powered by AI, not a simple script.' Fact: The law defines a bot as an automated online account where all or substantially all actions are not the result of a person. Whether it runs on modern AI or a simple script makes no difference. What matters is the automation, the intent to mislead about its artificial identity, and the commercial or electoral purpose.

Misconception: 'This law only applies to political campaigns.' Fact: The law applies equally to commercial bots used to sell products and to political bots used to influence elections. Both are subject to the same disclosure requirement.

Frequently asked questions

Sources

• California SB 1001 (B.O.T. Act)
• California Business and Professions Code Section 17941