Customer-facing AI chatbots, virtual assistants, and automated response systems. Here is what Vermont businesses need to know in 2026.
Vermont does not yet have a specific law for this use case, but S.0018 — AI Oversight. Proposed AI oversight board and mandatory impact assessments for high-risk systems.
State law does not replace federal law — you must comply with both. These federal rules apply to chatbot disclosure nationwide:
Vermont's S.0018 — AI Oversight often includes size-based exemptions. Businesses with fewer than 25 employees may be exempt, but should verify thresholds. Always review the specific statute for employee count and revenue thresholds.
The key deadline in Vermont is July 1, 2026. The law is still developing — monitor for final rules.
Vermont penalties for AI non-compliance: TBD. While enforcement is still developing, companies found non-compliant face civil penalties and potential litigation.
Federal law does not currently preempt state AI laws. Vermont's S.0018 — AI Oversight applies independently of federal rules. Federal laws like ECOA, FCRA, and HIPAA also apply alongside state law — so you must comply with both.
Best practice: document all AI systems used, conduct an internal audit, implement required disclosures, and keep records for at least 3 years. For high-risk uses like chatbot disclosure, consider hiring an independent third-party auditor to validate compliance.
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