The Fifteen-Minute Chatbot Rule Is Law. Can You Prove You Tried?
Signed on September 28, 2026, California AB 1609 covers customer service chatbots at large businesses. With this new law, when a customer asks a chatbot for a real person, the business has to try to connect them to one within fifteen minutes.
While this fifteen-minute deadline has gotten most of the attention, the law doesn’t say you must connect every customer within that time frame. Instead, the law says you must make a “good faith effort” to connect them.
What the Law Asks For
If your business has more than $500 million in gross annual revenue nationally and offers a customer service chatbot that people in California can use, here are the three main requirements:
AB 1609 also sets hold-time caps, excludes some channels, and includes penalties and exemptions. This legal breakdown covers the details, and this summary lists the exemptions. Health plans and payers should check with legal counsel, because it isn’t yet clear whether they’re covered.
While it hasn’t been officially confirmed, the law is expected to take effect on January 1, 2027, under California’s general rule for new laws.
The “Good Faith” Standard in AB 1609 Is About Evidence
One legal analysis describes the “good faith effort” in AB 1609 as “commercially reasonable and practical standards that are designed and intended to achieve compliance.”
These questions put the spotlight on your handoff from chatbot to agent. A handoff that was built in from the start is easy to point to. A handoff that was added on later is harder to defend, especially if the customer has to repeat everything to the agent.
Keeping a record works in your favor, too. A call that misses the fifteen-minute mark isn’t a violation by itself, but you’ll need the details of that call to show you tried.
Six Things Your Record Should Show
Pick one recent call where a customer asked for a person. Can your team answer these six questions about that one call?
If your team struggled to answer all six questions, the details of that call are probably stored in more than one place. That’s common when the chatbot, the phone system, and the agent desktop each keep their own records.
The goal is one complete record for each call. If your systems are separate, put a procedure in place now for pulling those details together. That work takes time you may not have when a complaint comes in. The fewer places you have to look, the easier that job gets.
Wherever you keep these records, treat them as sensitive data. Ask any vendor about certifications such as HITRUST r2 or SOC 2.
More States Are Likely to Follow California
If AB 1609 doesn’t cover your business today, a similar law might soon.
Chatbot rules are moving fast. One tracker counted chatbot bills in 27 states this year. Most of those bills deal with safety and disclosure, not customer service. But California has now written the first set of rules for reaching a human, and other states tend to borrow from California.
Customer expectations will change faster than the laws do. Once big brands have to offer a way to reach a person, customers will expect the same from every business. That includes smaller businesses under the revenue threshold.
With this law, chatbots and AI will keep handling most customer questions. What changes is that the handoff to a human is now something you may have to prove, call by call. With a likely start date of January 1, 2027, now is the time to check your call records.
