Ban on minor-simulating chatbots

Full Title:
SIMS Act

Summary#

This bill would make it illegal for companies or people who offer chatbots to provide chatbots that simulate minors in sexually explicit conduct or sexually explicit conversation. It adds a new federal offense, defines key terms for chatbots and minors, sets civil and criminal penalties, and gives the Attorney General powers to enforce the rule and write regulations. The stated goal is to stop simulated sexual interactions that involve characters presented as children.

  • Main change: Prohibits covered entities from making available chatbots that simulate a minor engaged in sexually explicit conduct or conversation that is obscene and would violate criminal law in the relevant place.
  • Who is covered: Any person who owns or operates a chatbot made available to people in the United States.
  • Penalties: Willful violations can bring a criminal fine up to $100,000 and civil penalties up to $100,000 per violation, plus injunctions and other relief.
  • Exemptions: Federal, state, local, and some foreign law enforcement agencies may get limited exemptions from the ban for investigations of child sexual exploitation. Research and testing to determine whether a chatbot violates the rule are protected.
  • Enforcement and oversight: The Attorney General may investigate, issue subpoenas, make rules, and must send an annual report to Congress with counts of prosecutions, penalties, investigations, and other relevant information.
  • Timing: The rule would start 180 days after the law is enacted.

What it means for you#

  • Chatbot operators and developers

    • If you offer a chatbot to people in the U.S., you must not provide a chatbot designed to simulate a minor in sexually explicit conduct or conversation that is obscene and criminally unlawful.
    • You could face civil penalties up to $100,000 per violation and a criminal fine up to $100,000 for willful violations.
    • You may need to change training data, models, prompts, user controls, and content filters to comply.
  • Technology companies and platforms

    • Platforms that host or distribute chatbots may need to check whether any chatbots they list could fall under the ban.
    • Platforms may face enforcement actions and must respond to subpoenas or investigations from the Department of Justice.
  • Researchers and security testers

    • The bill says it does not bar internal or external research, red-teaming, or publishing results that assess whether a chatbot violates the rule. Practical details about how researchers must document or limit such work are not spelled out.
  • Law enforcement

    • Federal, state, local, and certain foreign agencies can request exemptions for investigative use of a chatbot that would otherwise be banned.
  • Users

    • Users would lose access to any chatbot that deliberately simulates a minor in sexually explicit content that meets the bill’s definition of obscene and unlawful.

Expenses#

No publicly available information.

  • The bill itself sets monetary penalties: criminal fines up to $100,000 for willful violations and civil penalties up to $100,000 per violation.
  • The Attorney General may use investigatory tools, issue subpoenas, and write regulations. These actions could require staff time and legal resources inside the Department of Justice, but the bill gives no cost estimate.
  • Covered entities may face compliance costs to modify or block content, update systems, and respond to investigations or lawsuits.
  • There is no fiscal note or budget estimate included in the provided material.

Proponents' View#

  • The bill appears intended to close a gap for AI-generated or simulated content by making it unlawful to provide chatbots that present minors in sexually explicit situations.
  • Supporters may argue this would protect children by removing tools designed to simulate sexual interactions with minors.
  • The bill gives law enforcement a path to use similar tools in investigations through a formal exemption.
  • The annual reporting requirement aims to provide oversight and data on enforcement and use of chatbots in investigations.

Opponents' View#

  • One concern is the bill’s definitions could be unclear in practice. For example, what counts as a chatbot “designed to simulate” a minor or as “sexually explicit conversation” may be open to interpretation.
  • The bill ties illegal conduct to both obscenity and what would be criminal in the relevant jurisdiction. That dual test may create uncertainty for companies operating across state or international lines.
  • It is not clear how the research exemption will work in practice or what documentation researchers must keep to avoid enforcement.
  • The Attorney General’s power to write regulations and issue subpoenas could lead to broad enforcement choices; the bill does not set detailed limits on that process.
  • There is no public cost estimate for enforcement or for the compliance burden on businesses, so the scale of administrative or legal costs is unknown.